August 12, 1998

          Jonathan G Katz, Secretary
          Securities and Exchange Commission
          450 Fifth Street N.W.
          Washington D.C. 20549

          RE: File No. S7-8-98 -

          Dear Mr. Katz:

          On behalf of The Montana Company, I am submitting comments on
          your proposal that will require non-bank transfer agents to
          engage independent public accountants to attest to specific
          assertions included in the agents' reports on Year 2000
          compliance efforts.  We appreciate the Commissions concerns
          regarding Year 200 challenges and this Company is deliberately
          executing plans to assure its essential systems operate
          effectively.  Further, the Company appreciates the public's
          interest in full and complete disclosure.  We do not believe,
          however, using independent public accountants to judge the
          effectiveness of a non-bank transfer agent's compliance effort
          and, through attestations report this judgment is appropriate.
          Rather, accountants should be used to perform specific procedures
          for clients to assist the client's preparedness efforts.
          Accountants may also test the client's on-going work and report
          the results of there tests to assist the client in making
          judgments regarding the success or likely success of its
          preparedness effort.  The Company appreciates the Commission's
          role that may conclude requiring non-bank transfer agents to
          employ public accountants that will contribute to the perception
          that the public may have a greater degree of confidence in the
          Year 2000 preparations.  Such an intervention by the Commission,
          however, is unnecessary.  The Company is deliberately and
          programmatically addressing it systems and operations that may be
          affected by Year 2000 issues and is disclosing its work through
          the requirements of Rule 17Ad-18.

          Sincerely,

          Rose Marie Ralph
          Assistant Secretary and
          Director of Corporate and Shareholder Services Department