Date:    2/5/98  1:25 PM
Subject: 33-7475.txt
     
Dear Sirs:
     
Interstate/Johnson Lane, Inc.  is  a NYSE listed company whose largest   
subsidiary is a full service regional broker-dealer.  We thus have an   
interest in householding issues both as an issuer and as a BD servicing   
street name and client name accounts.  We applaud the SEC's effort in   
this regard, as the receipt of multiple mailings is  a source of constant   
complaint from our clients, and it represents a huge extra cost to   
issuers and BD firms.
     
We think the proposal is well intended but should be expanded a bit:
     
 The householding delivery should be allowed for all types of documents,   
and for  all types of corporate events. For example, it is in the   
issuers' (or anyone's) interests to obtain as high a vote count as   
possible for proxies, and any additional requests for documents or   
complaints about insufficient delivery of proxy statements will therefore   
be handled promptly and easily.    This should be the case whether the   
account holds securities in street name or has their securities in their   
possession or in the "broker box".
     
The rules should allow the investor to decide how mailings are addressed.   
We do not think many annual report or proxy mailings appear to be junk   
mail, and do not think having a personal addressee will have any effect on 
that perception.  Moreover, if information is time sensitive, having mail 
opened by the first person in the family to see the mail, for instance, 
may help important items come to the attention of the proper persons in 
the household in a prompt  manner.  This may be more likely if the mail is 
addressed to the family as a whole.  Moreover, this really is the type of 
decision that the investors should have the freedom to decide by themselves.
     
Similarly, the rules should allow continued reliance on notification and   
negative consent for householding.  Again, most people want less mail,   
not more, but they also can be difficult to get to reply concerning  
something they think may not be of much import to them at the moment.   
Again, if the client misses something because of householding and wants   
to obtain a copy, he or she will notice if it is important to them and   
will request extra copies.
     
In sum, the Commission  has put forth a great common sense proposal. Do   
not hamper its usefulness by trying to limit or circumscribe or   
over-think it too much.  Thank you for the proposal and for the   
opportunity to comment.
     
Sincerely,
     
Interstate/Johnson Lane
By,  Michael D. Hearn, Esq., General Counsel and Secretary