Subject: File No. S7-13-04
From: John T. W. Pace

June 14, 2004

Thank you for the opportunity to respond.

Our customers mainly keep their their money in their
local bank. Upon purchase they send us a check in
settlement. Few keep money in their Brokerage account at our correspondent for more than a short while. Although They could wire setllement funds it would complicate their buying from us and cause unnecessary expense for them.

I feel it gives the banks an unfair advantage over small broker-dealers.

Tom Pace
President, Cape Securities, Inc
Jacksonville, N.C. 28540