Mitchell Carucci 33 Lighthouse Rd Great Neck, NY 11024 (516)482-8256 ------------------------------------------------------------ Jonathan G. Katz Securities and Exchange Commission Mail Stop 6-9 450 Fifth Street N.W. Washington, D.C. 20549 REF S7-3-98 April 26,1998 Dear Mr. Katz, It has come to my attention in the past few days that changes have been proposed to rule 15c-2-11. After reviewing these changes, I feel that the result will be less competition in the market for small stocks. Since it is the goal of the SEC to insure that free and fair markets exist, I don't see how these proposed changes will lead to that end. In fact, I believe that just the opposite will occur. The changes to this rule will cause fewer traders to make markets in these small issues, and that will mean a less competitive market. I have been an investor in small stocks for many years. The only real protection that I have is that provided by a competitive marketplace. Competition is the key to fair pricing. Please do not make changes that will stifle this competitiveness. Thank you for your attention to this issue. Sincerely, Mitchell Carucci