Date:    12/9/98 4:26 PM
     
     
Johnathan G. Katz
Securities and Exchange Commission
450 Fifth Street N.W.
Washington, D.C. 20549         

Re: File No S7-26-98
     
Dear Mr. Katz:
     
        I appreciate the opportunity to comment on Re-proposed 
Books & RecordsRule.   Although I cannot speak for them, most 
Local firms share many of the same challenges and concerns
 regarding this proposal.
     
        Firms already require of their sales staff new account 
forms that contain information on the client's investment 
experience and financial background.  It is an important 
document maintained at the firm.  
     
However, the account record is not the only record maintained,
and it should not always be the primary determinant of suitability/unsuitability in arbitration proceedings.  A broker 
in dealing with a customer will gather additional suitability 
information that should not be supplanted in a legal proceeding 
by the customer account form.
     
The original proposal on customer records contained comment on 
the categorization of customer's investment objectives.  Comments 
were made on how frequently objectives can change, and that the 
terms used in the original proposal were imprecise. The 
re-proposal eliminates some of the imprecision of the original, 
and creates new ones in other areas. Who will define the required 
information in the categories on the account record? 
     
        Who should be considered the customer as it pertains to the Customer Account Record? Are the records to be maintained on 
each individual associated with an account, the individual who 
opens the account, approves any transactions, pays for any 
purchases?  
     
        The process of furnishing the customer account record to the client is time consuming and costly.  Much will have to be done
 manually. If the customer does not respond, do we need to note 
that on the customer records?   If so, that means all of our 
account records will be updated, not just 10% as estimated.
     
  Sincerely,
     
William C. Alsover President
Centennial Securities Company
3075 Charlevoix Drive SE
Grand Rapids, MI 49546