Date:    01/31/2000  10:55 PM


Subject: SR-NYSE-99-47
To those whom it concerns regarding SR-NYSE-99-47:
     
I no doubt feel you have heard from many people in any range of topics.  My 
comment will be simple as I probably share the same views of many of those who 
have already corresponded to you on this matter.  I have been daytrading on a 
full-time basis for 18 months, and my beginning venture capital was everything I
could scrape together, $10,000.  It took 12 months for me to get to the point 
where I began to grasp and recognize how to predict tops and bottoms on stocks 
so as to ascertain a high percentage entry and exit point.  Daytraders, like 
millions of other Americans who pursue self employment, many fail the first 
year.  This is a business like any other, if you speak to daytraders who have 
made it into the second year, the success rate to profitability is greatly 
increased like any other small business.  As time goes bye that success rate 
gets greater as does the income.  As for myself, even through this volatile 
market we are currently experiencing, have made $23,500 in the last 90 days and 
will be happy to show confirmations if requested.  I do this with as little as 
$8000 and no more than $14,000 in my account at any one time.  Furthermore, I 
accomplish this by doing small scalps on momentum stocks.  I try to hit 
"singles" every day, those who do not exit a position if it moves away from them
or try for the "homerun", usually don't last too long.  I have succeeded at 
doing what most fail.  If you change the current rules of trading you will most 
certainly put me and many others out of business.  Does someone with a bigger 
account trade better than someone with a smaller account?  I think not!  If 
anything, perhaps you should place a cap on those who enter daytrading so they 
will not lose tens, if not hundreds of thousands of dollars.  Perhaps my 
greatest motivation was my lack of capital.  I knew if I lost my money and did 
not adhere to strict guidelines for a successful trader then I would put myself 
out of business.  If a trader has a small account and trades by your rules with 
no margin, you'll find those traders will hold positions longer in order to make
$ because they will probably do no more than 1 trade per day.  at some point it 
will most certainly go against them and the very rules you have put in place to 
"help" people will be the  very rule that puts them out of business.
     
PLEASE GIVE ME THE SAME OPPORTUNITY AS THOSE WITH A BIG ACCOUNT, I ASK ONLY FOR 
A CHANCE TO SUCCEED.
     
Thanks
Mark Shepherd
PO Box 7632
Dallas, TX
75209
214/244-4234