Date:    4/6/99  2:21 PM

Subject: File No. S7-5-99

ASIA PROPERTIES, INC.
12707 High Bluff Drive, 2/fl
San Diego, CA 92130
Tel 619-350-4288 Fax 619-350-4289
     
     
Jonathan Katz
Secretary, Securities and Exchange Commission 
Mail stop 6-9
450 Fifth street, NW
Washington, DC 20549
     
April 5, 1999
     
Re:  File No. S7-5-99
     
Dear Mr. Katz,
     
     
I am writing to you with regards to the proposed amendments to Rule 
15c-2-11, the rule that governs quoting stocks on the OTC bulletin board & 
pink sheets.  
     
My company Asia Properties currently trades on the OTC pink sheets and 
relys on market makers to provide liquidity and trading for our stock. 
Your proposal, while well-intentioned in it's efforts to curb micro-cap 
fraud, infact will just impede legitimate marketmakers such as our own: 
PUBLIC SECURITIES & SHARPE SECURITIES as they will then be risking 
considerable liability in trading our stock.  As we are a very small 
company, it will not be worth the expense & effort for such market makers 
to trade our shares considering the liability involved.
     
This new rule amendment shift the majority of responsibility to market 
makers from the SEC which trade these stocks.   This will result in shares 
like our own, being "shunned" by any market makers.
     
Speaking on behalf on my company and the 300 plus share holders, we totally 
oppose this new rule amendment.
     
Sincerely,
     
     
Daniel S. Mckinney
CEO
     
     
cc      Arthur Levitt, SEC Chairman
        Issac C. Hunt
        Norman Johnson
        Paul R. Carey
        Laura Unger