Date:    02/15/2000  10:58 PM

Subject: File SR-NYSE-99-47

To whom it may concern:
    My name is Elliot Kim and I am a customer of Cornerstone Securites.  I am 
writing to submit my views on the proposed margin changes.
    The penalty suggested for generating a daytrading call has no logical 
basis.  Under the proposed rule change, the penalty assessed for generating a 
margin call can be vastly different although the dollar amount of the 
violation might be the same.  For instance, if a trader with a $25,000 
account and using 4:1 margin as an opening trade, purchases $100,001 worth of 
securites, conducts no more trades for the rest of the day, a call would be 
generated and the trader would be responsible for depositing $50,000.50 to 
cover the call.  However, the same $1 violation at the end of the day could 
result in an infinitely large call theoretically limited only by how much 
stock could be bought and sold within the day.
    Basing the penalty on the total cost of all securities purchased during 
the day is not reasonable as it causes disparate penalties to be assesed in 
different situations.  Furthermore, what relevance does the total cost of all 
securities purchased that day, have to do with a call being generated, if all 
the previous trades were conducted without violating one's buying power?  The 
penalty assessed must be based on the dollar amount of the violation itself, 
or the actual amount by which buying power was exceeded.  With the increased 
buying power, a penalty of 50% of the violation amount is still a greater 
penalty than what is currently assessed, because the violation is being 
generated with 25% actual capital rather than 50%.  In this way, all margin 
calls can be treated equally and fairly.  Thank you for your time in this 
matter.
     
Sincerely,
Elliot Kim