920 Second Avenue South
  Minneapolis MN  55402
  612-370-2899
  Small Cap Stocks in Big Cap Markets 
  John G. Kinnard & Co.

  April 29, 1998

  Jonathan G. Katz, Secretary
  Securities and Exchange Commission 
  450 Fifth Street, NW
  Washington DC  20549

  Re:     SR-NASD-98-21

  Dear Mr. Katz:

        We strongly and totally support the proposal by the National
  Association of Securities Dealers ("NASD") to allow market makers to 
  quote their actual size by reducing the minimum quotation size
  requirement for market makers on all securities listed on Nasdaq to 
  one normal unit of trading.

        We are reassured that the published economic studies supporting 
  the NASD's proposal confirm that "actual size" has had no adverse
  effect on the quality of the NASDAQ markets for the 150 stocks that 
  are the subjects of the pilot program.  Correspondingly, the NASD's 
  findings have been validated by the hands-on experience of industry 
  participants, including many who are professional market makers.

        It is important that the actual size proposal be accepted for 
  several reasons.  It would allow firms to manage the risk process as
  it goes to the use of their capital, thereby insuring the transparency 
  and liquidity required for our investors today.

        In addition, without strong continuous markets in NASDAQ stocks, 
  the ability for corporate America to raise capital would be adversely 
  affected and this could have dire consequences for the long term
  economic foundation of capitalism.

        Another strong factor for approving the rule change is that the 
  adoption of the SEC's Order Handling Rules in 1997 has removed the
  rationale for mandating quote size.  Customer orders are now displayed 
  in the quote which has altered NASDAQ's structure from a predominantly 
  quote-driven market toward a more order driven market.

        We urge the Commission to approve the proposed rule as promptly 
  as possible.
  
        Respectfully,

        Arthur J. Kearney
        Director of Capital Markets
        John G. Kinnard & Co.