Saturday, May 15, 1999

To: Securities and Exchange Commission

From: Ron Owens

7104 Linden Dr

Anchorage, AK 99502

S7-16-99 Licensing Requirement for off floor traders.

Thank you for allowing me the opportunity to comment on the above-proposed change. I feel some type of licensing requirement will better serve the industry. But for many traders like myself who make a living trading stocks. But do not engage in outside money management, offering investment advice or executing trades for anyone other than my own account, Should not be required to pass a test specifically designed for Brokers, Securities Dealers, and Management Employees of the firm.

I would like to propose the NASD 55 test be considered for licensing purposes rather than the S-7 overkill. The S-7 requirement for off floor traders would not be unlike requiring a meter maid to pass the Bar Exam.