Date: 4/6/99 3:08 PM Subject: Re file # S7-5-99 Dear Mr. Katz, Re File # S7-5-99 My firm has been a market participant in the pink sheets and the OTC Bulletin Board since 1978. We specialize in dormant securities of high intrinsic value. From a commercial point of view, the proposed amendments would lead to our withdrawal from quoting many companies' shares. I can't expect the social engineers who proposed these amendments to care for my firm's financial health. I would hope they'd realized the deleterious effects on the trading liquidity of many shares and the consequent reduction in value to the shareholders of this country. Sincerely, Robert E. Kelly, CFA