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To: Frank Walker who wrote (155)	4/19/1999 2:34:00 PM
From: Anaxagoras	Respond to of 292

<<Does anyone know how to find this 15c2-11 ?>> Sorry, I don't know anything about Kaiden, and the only thing I know about a 15c2-11 is that it's a so-called "Application for Listing on a Public Exchange"- the only reason I know that is because I just ran across an OTC BB stock that was mentioned in connection with it. Anaxagoras

To: Frank Walker who wrote (155)	7/16/1999 9:36:00 PM
From: Frank Walker	Respond to of 292

Wash trading, anyone ? I am researching a stock called Crys-Tel (otc CYSS) and wonder if anyone access to tick (real-time trade) data for the last few weeks, and can interpret this data. I'm wondering if there is any sign of "wash trade" activity. The stock was practically dead at $0.75 to 1.00 a few weeks ago and now trades around $2.50 with heavy volume, for no apparent reason. Thanks, ILikeGorillas PS Here is some reference material about how a "wash trade" is done: asx.com.au sec.gov

To: Frank Walker who wrote (155)	7/22/1999 3:30:00 AM
From: The Duke of URL©	Respond to of 292

I: (off the top of my head, un-researched answer) 15c2-11 is first a regulation section under Title XV of the '34 act. It has a list of requirements that have been phased in to take effect about now and it applies to restrict a stock from being electronically traded. Sort of. It requires at least one MM/licensed BD to verify that a company actually exists before it can now trade. This has proven to be somewhat of an insurmountable obstacle for some of our most beloved stocks. The last time I looked at this was about a year ago, so this analysis is not intended to be relied upon. The "form" would contain places for the answers to the issues required in the regulation. The mechanism for restriction requires that the primary MM "vouch" that the financial statements are "current" and sort of correct. They don't want that responsibility so that means that not only does the company have to have financial statements (oh, Brave New World), but that they should be Certified, unless of course, the MM wants to "certify" them. So, if there is compliance with 15c.... then the lead MM must maintain a copy AND, if memory serves, must make a copy available to Usted. Duke.

To: Frank Walker who wrote (155)	7/22/1999 11:53:00 AM
From: The Duke of URL©	Read Replies (1) \| Respond to of 292

Igor: Here ya go: Rule 15(c)2-11(a)(5)(xvi) "If such information is made available to others upon request pursuant to this paragraph, such delivery, unless otherwise represented, shall not constitute a representation by such broker or dealer that such information is accurate, but shall constitute a representation by such broker or dealer that the information is reasonably current in relation to the day the quotation is submitted, that the broker or dealer has a reasonable basis under the circumstances for believing the information is accurate in all material respects, and that the information was obtained from sources which the broker or dealer has a reasonable basis for believing are reliable. This paragraph (a)(5) shall not apply to any security of an issuer included in paragraph (a)(3) of this Section unless a report or statement of such issuer described in paragraph (a)(3) of this Section is not reasonably available to the broker or dealer. A report or statement of an issuer described in paragraph (a)(3) of this Section shall be "reasonably available" when such report or statement is filed with the Commission."