Date: 1/28/98 10:14 AM Subject: S7-18-97 Rel. No. 34-38800; File No. S7-18-97 I agree that electronic filing should be an option for Form 13f. However, I wholly oppose a monthly filing within 5 days of period end. The reasons are as follows: 1. TIMEFRAME IMPOSSIBILITY. Investment advisory firm's who do not have physical custody of client's assets MUST wait for the cusodian (brokerage firm, bank, trust company) to send a final statement of the client's holdings and transactions. Without these statements, the investment advisor cannot reconcile with the custodian nor can the advisor accurately report on Form 13f. Most custodian's and brokerage firms send out their client statements between the 5th and 26th day of the month after the reporting period end(also some custodians send client statements out only quarterly). 2. HARDSHIP FOR SMALLER FIRMS. According to the Paperwork Reduction reports, Form 13f requires 24+ working hours to complete. For a small advisory firm, such as ours, with only 3 full-time employees, this would create a significant hardship for the firm's proper operation. Alexandra Sanderson, VP Sanderson Capital Management, Inc. Ithaca, NY (607) 257-5117