Subject: S7-8-97
Date:    4/15/97 11:44 AM
     
     
I am Dennis Brovarone, Attorney at Law, 11249 W. 103rd Dr., Westminster, 
CO 80021.
     
I completely agree with the concepts of requiring issuers to disclose 
unregistered sales in their SEC reporting as this informs the market as to 
changes in the public float.  I also completely agree with leveling the 
playing field for all investors and the coordination of Reg S and Reg D, (if 
not the elimination of arcane duplication).
     
I also believe that the concept of reporting short term market sales has a 
beneficial market information effect while being a reasonable burden on 
investors who may well be presumed to have obtained a discounted price and or 
material inside information in the course of making their direct investment 
with the issuer.
     
However once the market has been informed of the unregistered sale and the 
issuer has otherwise updated its disclosure for the possible inside 
information, the expiration of time unnecessarily burdens the investor and 
thereby increases the discount cost and ability to raise capital.  After all, 
for many if not most stock issuances which are publicly traded, the investment 
intent is to gain through subsequent sales, whether long or short term rather 
than retention for current income.
     
I recommend that the holding period for Form 144 resale be ninety days and 
that all restrictions be removed after one year.
     
Sincerely,
     
     
Dennis Brovarone