Date:    02/15/2000  2:59 PM

Subject: Comment on Proposed Rule Changes (SR-NYSE-99-47)

To Whom It May Concern:
     
I represent clients who are individual investors and am an attorney familar 
with the
securities industry. 
     
I feel that the proposed rule changes(SR-NYSE-99-47)discriminate 
unfairly against the public, particularly day traders and in reality are 
a poorly veiled attempt to discourage such trading.  
     
Under the "Purpose" ofthe proposed rule changes, the SEC states that "The 
primary 
purpose of theproposal is to require that minimum levels of equity and 
margin 
be depositedand maintained in day trading accounts sufficient to support the 
risks
associated with day trading activities."
     
The main item that I find troubling is the section under the Special 
Requirements for Pattern Day Traders.  If the day trader trades in excess of 
their day trading buying power, the account will be margined based on the 
cost of all the day trades made during the day.  This in no way is related to 
the actual risk incurred by the day trader at any one time and seems like an 
arbitrary punishment for exceeding one's buying power.
Additionally, day traders are being singled out unfairly by forcing them to 
meet margin calls on the same day rather than the standard three days used 
by Regulation T and Maintenance calls.
     
It appears to me that the SEC, in proposing this change is attempting to 
discourage 
day trading altogether rather than trying to addressing the risks associated
     
with that particular investment strategy. I respectfully submit that this 
heavy
handed approach seems over-reaching in scope, in that individuals should be 
given the freedom to invest as they choose and should not have their 
livlihood
threatened inappropriately by our federal government.
     
Cristi M. Ray
Attorney and Counselor
Munsch Hardt Kopf & Harr, P.C.
111 Congress Avenue, Suite 2010
Austin, Texas  78701
512.391.6112   
512.391.6149   Fax