April 5, 1999

Jonathan G. Katz

Secretary, Securities and Exchange Commission

Mail Stop 6-9

450 Fifth Street, NW

Washington, DC 20549

Dear Mr. Katz:

I am writing to express my concerns about the proposed amendments to Rule 15c2-11. I am opposed to the changes in File No. 57-5-99.

Please understand that these amendments affect me in two ways. Not only does my firm trade OTC Bulletin Board securities as a broker-dealer, but also the parent company's stock is traded on the Bulletin Board under the symbol BSGK.

I am opposed to these amendments because I should not be held liable for the accounting practices of publicly own businesses in which I do not hold a place in management or on the board. This liability belongs to management and the independent auditors that assist them. There is not enough money earned by trading on the OTCBB to compensate my firm for one adverse ruling under your proposal. Yes, I understand that the proposal has good intentions, but ultimately the investor must hold this liability to "know his investment". I hope you agree.


Banc Stock Financial Services, Inc.

Matthew E. Lee

Vice President of Equity Trading