April 1, 1999
Mr. Jonathan G. Katz
Secretary, Securities and Exchange Commission
Mail Stop 6-9
450 Fifth Street, NW
Washington, DC 20549
Re: S.E.C. Rule 15c2-11 Amendment, File No. S7-5-99
Dear Mr. Katz:
Speaking on behalf of Publishers Equipment Corporation (OTC Bulletin Board), I wish to voice my opposition to the proposed amendment to Rule 15c2-11. While this amendment is no doubt well intentioned, I believe that any potential benefits to our shareholders would be more than offset by the unintended consequences of the amendment, most significantly the likely exodus of market makers from OTC Bulletin Board stocks.
I believe that Publishers Equipment Corporation has been well served by the "Know Your Customer" rule governing market makers, and that the question of abuses should be addressed by identifying and punishing abusers, rather than imposing counter productive rules on the whole community. The additional burden that is proposed for the market makers, I believe, is more appropriately left where it belongs, with the Securities and Exchange Commission.
Thank you for your consideration of this request to reject the proposed amendment to Rule 15c2-11.
PUBLISHERS EQUIPMENT CORPORATION