03/19/99
     
Jonathan G. Katz, Secretary
Mail Stop 0609
Securities and Exchange Commission
450 Fifth Street
NW, Washington DC,   20549-0609
     
RE:    Comments on File No. S7-8-99
     
Dear Mr. Katz:
     
Our firm is a small Securities Firm  that does not receive or hold 
customer funds or securities, or carries customer accounts, nor do we 
interface with any outside third parties or outside vendors. We feel 
your requirements should be targeted toward those Broker-Dealers that 
have a minimum net capital requirement above $5,000.
     
     
     
US Particpations, Ltd.
Thomas J. Lonergan, President