Mr. Jonathan Katz
SEC
450 Fifth Street, NW
Washington, DC  20549
     
							April 13, 1998
     
RE: SR-NASD-98-21
     
Dear Mr. Katz:
     
Thank you for the opportunity to voice my opinion concerning NASD's 
proposed rule. This letter is written as a strong opposition to the Actual 
Size Rule (NASD Rule 4613 (a)(1)(C)).  As a professional securities trader, the 
impact of the 150 pilot stocks has greatly reduced my ability to trade 
in a liquid market, or rather lack of liquidity. 
     
The market makers have repeatedly manipulated the market price of a 
stock by using the ECN's to "block" a SOES trade from coming in.  The 
ECN's enter a small bid and then hold it and allow the market makers to 
reduce their shares.  Also, this allows for a larger spread because the 
market makers rapidly disappear.  
     
I have seen the spread go from a 1/4 to over a point because of this 
rule in the 150 pilot stocks.  In theory, the spread is still a 1/4; 
however once one takes a closer look, the ECN (non-SOESable) is holding 
a 100 shares at a particular price while the next market maker may be 
1/2 point away creating an effective spread of 3/4.   As a private 
investor attempts to buy or sell 1000 shares, his or her order is moved 
throughout several market makers with perhaps only 500 shares being 
filled and then his order is "kicked out" because of another ECN coming 
in. 
     
When the market is in adverse conditions, the market makers use this 
rule to effectively stop price movement by not providing liquidity.
They use 100 shares to form a block while they slow down the movement of 
the stock thereby reducing the liquidity of the stock.  Orders are not 
being filled by the spread, but by the effective spread created by the 
market makers.  A private investor may not get 1000 shares filled until 
1 point below the price because of 100 shares offered by an ECN 
virtually blocking SOES orders.  The ECNs literally "pop in and out" at 
every level with 100 shares at a time.
     
I invite any of you to view for yourselves what actually happens as 
compared to what some "survey" may say happens.  Real executions are 
different than what is being seen on the screen.
     
As a trader, myself and other fellow traders have repeatedly witnessed a 
market maker manipulating a stock to his benefit by reducing shares and 
'hiding" behind an ECN.  
     
It seems to me that the market makers are doing their best to reduce 
their risks at the expense of the public investor. 
     
 The market maker clearly has more distinct advantages:
        the margin required for a market maker to hold a position is
superior to that of the public investor
        the market maker does not need an uptick to short sell, as does
the public investor
     
To reduce the number of shares to 100 would give the market makers a 
huge advantage over the public investor.  Why should the bulk of the 
risk go to the public investor?
     
NASDAQ started the SOES system as a way to allow the public investor a 
means of market access.  Let's not allow the market makers to destroy 
this concept.
     
Let's keep liquidity in the market place so it is a fair system for all 
persons involved.  Thank you again for your attention to this matter.  
     
     
Sincerely,
     
     
Elinor Mire
2510 Friar Tuck Ln.
Austin, TX 78704
512-326-9082