Date:    7/31/97 4:11 PM
     
     
     
Jonathan G. Katz, Secretary
Securities and Exchange Commission
Email: rule-comments@sec.gov
     
RE: File No. S7-18-97, Request for Comment 
     
Dear Sir:
     
We would much prefer to file our quarterly 13F submission electronically. 
However, we have not filed electronically in the past due to the inconvenience 
of filing on magnetic tape and the reprogramming necessary to implement the 
specific formatting requirements.
     
We would enthusiastically support changes that "would provide for the filing of 
these reports by direct transmission and diskette as well as by magnetic tape".  
However, this support would be conditioned upon provisions that "[do not] apply 
the detailed formatting requirements of Form 13F-E to the mandatory electronic 
submission of Form 13F ... although the basic tabular presentation of data would 
be retained, as is currently the case with Form 13F reports filed in paper."  In 
other words, we would support the changes so long as they were reasonably 
friendly to comply with and made our submissions easier, not more difficult.
     
Sincerely,
     
     
     
     
Janet Small
Programming Area Chief
Rosenberg Institutional Equity Management 
4 Orinda Way Suite 100E
Orinda CA 94563
Phone: 510-253-3378
Fax: 510-253-3479
Email: j_small@riem.com