Subject: 33-7637.txt

Date:    05/28/2000 11:40 AM
     
     
Dear SEC
     
 You should re-open the comment period on this proposal.
     
     Assuming the foreign issuer registers a percentage of their shares
with the SEC, what would be your legal basis for requiring the issuer to 
try to discover the beneficial ownership of their unregistered stock?
     
     Of the securities registered with the SEC, how would the issuer
legally require a nominee to disclose the beneficial owner of their 
shares in the company to the issuer?
     
     The DTC maintains Objecting Beneficial Owners (OBO) list for each
company trading in the U. S. This OBO list is unavailable to the issuer. 
How do you propose the issuer secure this information?
     
     Has anyone computed the costs of trying to comply with your
proposed definition?
     
     Until there is global uniformity on GAAP, among all stock
exchanges, there is little hope that any single filing will fit 
everyone's needs.
     
Bill Cate