Subject: SR-NYSE-99-47
 
Date:    02/13/2000 10:43 PM
     
     
Dear Ladies and Gentlemen,
     
I'm writing you this letter to express my concern regarding the proposed 
rule changes from the NYSE and NASD for Daytrading acounts .
First of all I understand that you want to protect people with a small 
amount of money from the risks that Daytrading obviousely faces. I know 
that there has been alot of Daytrading "desasters", but there are also 
alot of people who really make a great living on Daytrading .
     
1. The new rule would allow you to use 4:1 margin , even if thats ment 
to be the amount of total equity you can buy on a single day ,it still 
makes not alot of sence to me cause the risks of having that much buying 
power is obviousely very high??
     
2.Why raising minimum account requirements to $25 K ?? As far as I 
understand by raising requirements you want to make people aware of the 
risks Daytrading faces . I agree $ 25K would make sence on that 
issue...but most of the people I know of like to have about $ 15K or 
even less in their account , they dont like having more of that in their 
accounts because it helps them managing their risks .
Does $ 25K make sombody a better Daytrader ?? I seriousely doubt 
that...I would say somebody who starts Daytradng with very little money 
has even a more disciplined approach to it ,cause he knows , that he 
needs to be very disciplined in order to succeed . I met alot of people 
like that. I met more people starting with $50K and loosing alomost all 
, than people with less than $10K . Those small guys usually still have 
a regular job and take alot of time learning Daytrading rather than 
taking alot of risk and wanting to become rich over night.
Also I think that alot of people who are currently Trading or planning 
to ,will than borrow additional money in order to start . That could 
actually become a more  serious issue than you might think imho...!! 
And isn't this unfair to the "smaller guy" , I would even say it's 
discriminating .
I always thought the US is the Land of opportunity !
     
But how do we protect people ?
Frst of all sombody needs to be made completely aware of the risks he's 
facing when Daytrading , maybe even more than that's currently the case 
. I woud also be more than sensitive about misleading advertisements by 
Brokerage Firms ( very dangerous imho).
The worst Daytrading story's I've heard of came from people shorting 
stocks, that than went thru the roof ...maybe you want to lower buying 
power when shorting stocks ?
I 've heard of people running into "loosing streaks ", maybe one could 
be stopped from Trading if the person already has lost a certain 
percantage of their portfolio on that particular day !
You might also want to require some tests for people willing to Daytrade 
in order to make sure that they know  how Daytrading works ,  how to use 
software and order entry systems ,and most important to make them 
completely aware of all the little "proplems " that one has to master in 
order to become succesfull. What many people dont seem to understand is 
the huge difference between trying Trading strategies in theory ( on 
paper  ) and Trading with "real " money .
     
Thank you
     
Hans-Peter Clever
Germany