Subject: File No. S7-5-99
Author:  <echess@pacbell.net> 
Date:    5/6/99 2:08 PM
     
     
As an attorney, I am opposed to the proposed amendment to Rule 15c2-11.  It 
is an ill advised attempt to bring liability to the brokerage community at 
the expense of liquidity to smaller cap companies.  While there may be 
financial information abuses by small-cap non-reporting companies, it is the 
obligation of the companies themselves and the accounting professionals to 
adhere to appropriate standards.  Forcing the brokerage community to become 
a financial watchdog for these small companies will only make listing of 
such companies cost inefficient.
     
Regards,
     
Eric Chess Bronk