Date:    4/7/99  9:33 AM

Subject: File S7-5-99

The amendments to Rule 15c2-11 apparently are extremely short sighted.
I appears that the legal responsibility should lie with the company, not 
with the party who quotes a price on the company.  If the party who 
quotes the price is legally responsible for the quote, then obviously, 
the price of that security should reflect the ownership of that security, 
since the quoter is responsible for the financial reports of that 
company, he should reap the rewards as well as suffering the consequences 
of the financials, it should not be a one way street, where a market 
maker is responsible for the financials of a company, but is unable to 
benefit from that financial information. Given that the quoter is unable 
to benefit from the price, the only persons who will be quoting will be 
the people who don't really care, because they will go out of business if 
a lawsuit is instigated, in other words, the only people willing to give 
quotes on questionable companies, won't be there when the investor is 
burned. 
     
We are against the policy as proposed.
     
Very truly your,
     
Richard Bredhoff
Earnhardt Co., Inc.
Member, NASD, SIPC