Subject: File S7-3-98
Date:    4/24/98 8:41 AM
     
     
I would just like to go on record as saying that I favor any increased 
regulation or scrutiny over bulletin board and other stocks not on any 
nat'l exchange. While the listing and maintenance requirements of 
NYSE, AMEX and NASDAQ cannot by themselves prevent an out and out 
scam, they at least help establish some kind of standard against which 
the financial health can be measured, and reflect a professional's 
current monitoring of that health. On the other hand, a company can 
back it's way into a BB stock, make no filings, yet trade actively.
     
The transmission of communications has expanded greatly thru the use 
of the internet. There are far too many novice, and even expert, 
investors constantly being hyped by unscrupulous operators of websites 
with stories of such and such a stock jumping xx% today. While I have 
made some money on BB stocks, it was only after some rigorous 
investigation. Where I failed to due my own due diligence, I usually 
lost money, and severely in one company that turned out to be a total 
scam and should have been halted long before by the SEC, as the only 
agency that could do so.
     
I would also like to see NASD have greater powers to intervene, halt 
trading, and investigate claims of BB companies than at present. The 
relatively few companies that are either totally fraudulent or at 
least borderline hurt the entire industry, and investors. To date, it 
does not appear that SEC has the ability, willingness or staff to act 
in sufficent time in light of the increased internet activity.
     
Placing a greater burden on market makers to do their due diligence 
prior to making a market may well reduce the number of active 
participants, thereby hurting liquidity on some. However, those with 
clean and current financial reporting, and responsive to requests for 
information, are not likely to have a significant problem. I recently 
interviewed for a job with a market maker in about 2000 stocks, many 
of which are BB stocks. I asked how the proposed regulations would 
affect their BB business, and was told it would have little effect 
other than increasing their internal workload to not only do the due 
diligence, but ensure it is maintained current.
     
Any loss in the number of marker makers or liquidity is more than 
offset by greater safety for investors. Any legitimate company, than 
is only able to go public on the BB, is likely better off staying 
private for a few more years and gaining sufficient strength, and 
financial health, until it can gain NASDAQ listing.
     
Tom Worley