Subject: Rule 15c211-11 amendments Author: "jack l. howard" Date: 5/5/99 11:43 AM May 5, 1999 Jonathan G. Katz, Secretary Securities and Exchange Commission 450 Fifth Street, Northwest Washington D.C. 205049 Re: File No. S7-5-99 Dear Mr. Katz: I am submitting this letter in response to the request of the Securities and Exchange Commission (the "Commission or the "SEC") for comments on Release No. 41110 regarding certain proposed amendments to Rule 15c2-11 (the "Proposed Amendments") under the Securities Exchange Act of 1934 (the "Exchange Act"). I understand these Proposed Amendments are to reduce fraud in the microcap market. I oppose substantial parts of the Proposed Amendments that focus on legitimate market makers. I feel forcing market makers to try to find fraud and then to stop trading a security and report fraud will not reduce fraud. It very likely will hurt liquidity and could possibly leave dishonest firms trading securities, which could hurt investors further. I am the president of Gateway Industries (otc-gway) and CFO of Rose's Holdings (otc-RSES) both of which trade on the NASDAQ bulletin board. Our shares trade very infrequently and I believe that your Proposed Amendments should be altered so that it won't force market makers to quit trading OTC securities. Please call me for more information. Sincerely yours, Jack L. Howard