April 13, 1998
     
Mr. Jonathan Katz
Secretary
Securities and Exchange Commission
Judiciary Plaza
450 5th Street, N.W.
Washington, D.C.  20549
     
RE: File No. SR-NASD-98-21
     
Dear Mr. Katz:
     
As a public investor and day trader I would like to voice my opinion in 
regard to the Actual Size Rule (NASD Rule 4613(a)(1)(C)).  The original 
1000 share SOES tier limit was implemented to provide liquidity to the 
market and insure a fair trading platform.  This came about because of 
Market Maker abuse, which in turn adversely effected the small investor. 
Since the implementation of the pilot program, I have witnessed many 
abuses on a day to day basis.  The most obvious one being an "ECN Block" 
where the Market Makers use a small order i.e. 100 shares and stop the 
order flow and then back away leaving virtually zero liquidity once the 
ECN is filled.  Another abuse, which has certainly hurt the liquidity, is 
when the levels outside of the inside spread often range from 5/8 - 1 
point.  For example, on any given stock the inside spread may be 1/2-5/8, 
but the next bid level is often 1/4 and the next ask level 7/8. So the 
effective spreads have widened while the Market Makers responsibility for 
liquidity has diminished.
     
I also find it alarming that the NASD's investigation into the liquidity 
issue was handled in-house instead of by an independent source.  Any one 
who reads financial periodicals or keeps up with the market knows how 
the NASD coddles the Market Makers and looks the other way at their 
abusive behavior.  So it should come as no surprise that the NASD 
believes this pilot program has shown any real difference in spreads and 
liquidity.  I believe that if an independent source were to look into 
this matter the findings would be substantially different than the 
NASD's.
     
Sincerely,
     
     
John H. Crabb  
12349 Metric Blvd. #1325
Austin, TX  78758