Date:    01/31/2000  5:52 PM


Subject: Comments to File Number SR-NYSE-99-47

Sirs,
     
The proposed rule changes, specifically raising the cash account requirements 
from $2,000 to $25,000 are discriminatory to the small investor and encourage 
them to place a larger portion of their assets in a daytrading account.  Indeed,
the change to raise investors to margin buying power from 2:1 to 4:1 gives small
investors more rope to hang themselves.   
     
Under your proposed change, a typical investor who now places $5,000-10,000 of 
his or her investment portfolio in a daytrading account will be "required" to 
place $25,000 in a daytrader account, forcing these traders to place a 
substantially larger percentage of their assets in a daytrading account, and 
encouraging them to trade in larger volumes and place a larger percentage of 
their portfolio and assets at risk.
     
Let's look at the typical small investor with $100,0000 portfolio.  The $10,000 
they currently trade is a relatively small percentage of their overall 
investment portfolio.  If they are required to have $25,000 on deposit to trade 
on margin, they will have to place 2.5 times more capital in their account, 
increasing the percentage of their daytrading portfolio from 10% to 25% of their
overall portfolio.  And under your proposed margin rule change, their 4:1 margin
account "encourages" them to trade stock representing 100% of the value of their
overall portfolio.   This is nonsense!!!!   Your proposed rule changes 
substantially increases the risk to the small investor, by encouraging them to 
place a larger portion of capital at risk.
     
Thank you for your consideration.
     
Rich Stucky