April 13, 1998
    
Mr. Jonathan Katz
Secretary
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC   20549
     
RE:  SR-NASD-98-21
     
Dear Mr. Katz:
     
My name is Patrick Holmes; I live in Austin, Texas and am a day trader. 
I would like to comment on the Actual Size Rule and how it has changed 
my ability to trade and make a profit.  
     
Trading has changed completely in the three years that I have been 
investing.  Obviously the actual spreads have widened since the Minimum 
Quote Size has been implemented.  The same trades that we could expect 
to be filled within a 1/4 to 1/2 a point; we are getting hit for 3/4 to 
point difference.  
     
The Market Makers seem to be backing away more often and not honoring 
their quotes.  Their ability to use the ECNs to stop the momentum of the 
stock is detrimental to the flow of the market.  
     
I think it is a bad idea to have the NASD run its own evaluation on a 
system that seems so Market Maker bias.  It just doesn't make sense that 
they would say that the markets depth and liquidity without regard to 
investor protection.  This Pilot Program should be terminated and the 
proposed rule rejected.
     
SOES was established to protect the small investor from the Market Makers 
who prey on them.  The NASD is made up of Market Makers, and they are the 
ones who have this program to study the results of the implementation of 
the rule for the first 40 stocks.  First of all, those stocks and the 
Market Makers knew they were being studied - they could easily manipulate 
the statistics.  But mostly, I believe they simply read the numbers the 
way they want too.  They are benefiting and the small investor is paying 
for it.  Please do a new study with an independent analist before passing 
on this rule change.
     
Please continue to do what you were established to do, Protect the 
investing public and encourage a liquid and equitable market.
     
Thank you for this opportunity to comment.
     
     
Patrick Holmes
1101 B Gaston
Austin, Texas  78703