Subject: File No. S7-5-99

Date:    4/6/99 2:16 PM
     
     
     
       I would like to voice my opposition to your proposed amendment to rule
15c2-11. Legitimate maket makers provide the investing public with liquidity and
stability in the stocks which they have invested in. This proposal will shift 
the SEC's responsibilities to the market makers.
    Market makers rely upon audited financial statements, which are prepared by
the company and audited by Certified Public Accountants. The cornerstone of the 
financial markets, is the fair presentation of financial information. This 
system has worked well since its inception with changes being made as the need 
arises. However to now make the market makers responsible for the companies 
financial information, shifts the entire burden of proof to the market makers. 
Will the market makers hire the companies auditors? Who will have to pay for the
audits? If the market makers have to pay for the audits will these costs be 
passed on to the investing public?
    If this amendment is passed the legitimate market makers will be forced to
drop all their markets. This will create havoc with individual investors because
the only way that they can sell their investments, is to go to the scam artists,
who are there for the quick buck. They will be able to manipulate the market in 
order to make the most money, and then get out before they get caught.
    No one would argue with rule changes which increase liquidity and stability
in the financial markets. This change will not do that and will only hurt 
investors. In my opinion this will destroy the over the counter market, thereby 
making it impossible for companies to raise equity money for expansion or for 
new ideas.
    I urge you to vote against this rule change, and try to formulate rules
which will help the industry and the investors.   
     
                                                Sincerely,
                                                Gary Hume
                                                ACAP Financial, Inc.