Date:    06/20/2000  12:57 PM

Subject: S7-24-99

My name is Boyd Zander
     
I'm an engineer and invest in the OTCBB as a way to supplement my income to 
the betterment of myself and my families future. I recognize the fact that 
there is room for manipulation of the OTCBB markets by market makers via 
short selling. Part of the reason they have this capability is due to the 
fact of rules and regulations that do not require them to adequately 
disclose the extent of their short sales. They are required to make a fair 
market but, manipulation, which is within their capabilities, can add to 
their bottom line. Whether or not they truly manipulate the markets is a 
separate issue beyond the fact that they are set into a situation where 
making a fair market can actually come into conflict with the human emotion 
of greed and increasing profit. This country and it's government has many 
instances where, even though impropriety is not suspect, it is protected 
against.  I request that you consider actions that will require reporting of 
short sales by MM even if for only the sole purpose to protect against 
impropriety and give the investor the confidence that, should he decide to 
purchase stock in an OTCBB company, his investment will move according to 
fair market forces rather than according to unseen agenda and influences.
     
     
Boyd Zander