Subject: SR-NASD-98-21
Date:    4/13/98 9:00 AM
     
  As the head of Nasdaq trading at Fahnestock, and as an active and
experienced market maker for 18 years, I would like to express my support for 
the amendment to NASD Rule 4613(a)(1)(c) - the Actual Size Rule.
     
  As NASDAQ has now become an order driven market, market makers who must
display a quote size greater than all other market participants are at a 
singular disadvantage, which, in some cases, can cause market makers to stay 
away from the inside market. This has the potential to reduce liquidity that 
could otherwise be enhanced with more participants available at the NBBO.
     
  Additionally, NASDAQ market makers are now the only participants in any
market, including the listed exchanges, that are forced to execute  more than 
a 100 shares (round lot), for their proprietary account and risk capital 
trading. NASDAQ market makers, representing orders at their specified limit 
prices, now execute orders at the displayed limit order price. Passing out 
orders and incurring execution costs, results in market makers effectively 
losing money on a great many transactions. To additionally require that market 
makers buy or sell lots of 500 or 1000 shares when they do not have an order, 
continues to test the rational of firms to remain active in their market 
making capacity. There does not seem to be a fair justification to continue 
putting market makers at greater risk than all other specialists.
     
  I thank you for the oppurtunity to express my views.
     
Gary Kaplowitz
Head of NASDAQ Trading
Fahnestock & Co.