Author: "Dr. A. G. Bradford; Jr." Date: 02/15/2000 1:48 PM Subject: File SR-NYSE-99-47 I am a customer of cornerstone securities and would like to comment on some of these proposed rule changes. I understand the purpose of these changes is to reduce the risk of total account loss to stock investors and to the securities industry. 1. Your definition of a pattern day trader would include investors who only trade moderately. While a low volume or inexperienced trader might benefit from helpful risk management, in this rule there is no effort to recognize the professionalism and proficiency of the experienced trader. If a formula that included experience, average number of trades per day, equity in the account, and the securities firm's experience with the trader to split the rules into a group for light volume and novice traders, and another for experienced professional traders. 2. Day trading calls and and single strike and your account is closed proposed rules amount to a death sentence for a trader for a mistake that may have been made by others and do not manage risk but impose a draconian penalty on the trader even the mistake is someone else's. I generated a Day Trading call a month back due to a computer error and an error at the securities firm, and had only 30 minutes to deliver $20,000.00 cash, which was physically almost impossible as I had left town on business. Just to find some one to deliver the check much less arrange for the money to get into our payable account on this short notice, I couldn't even sell stock to cover, even though the account had 50 times that much in equity. This penalty would have been millions, even though these were a very profitable trades, and there was no risk as all contracts were cleared before I left that morning, and I was told every thing was clear, but was contacted that afternoon late to say their had been a computer and bookkeeping error. respectfully yours, A. G. BRADFORD