Comment on s7-41-04

John C. Burch, Jr. Bruce S. Foerster Capital Markets Advisors, LLC Aurora Capital, Inc. st2200 21 Avenue South 8360 West Oakland Park Blvd. Suite 228 Suite 201 Nashville TN 37212 Sunrise Fl 33351-7338 jburch@capitalmarketsadvisors.co brucef@auroracapital.net 615-292-6323 954-749-2030 X-161 February 15, 2005 VIA E-MAIL Jonathan G. Katz Secretary Securities and Exchange Commission 430 Fifth Street, NW Washington DC 20549-0609 RE: Comments on Amendments to Regulation M: Anti –manipulation Rules Concerning Security Offerings. - File Number S7-41-04 Dear Mr. Katz, As former investment bankers who were directly involved in hands-on positions of leadership and accountability in the management of over 1500 new issues of securities during 60 + years of collective experience, we share a deep love and respect for and an avid interest in the practice of investment banking and the so-called new issue process. We have maintained an active role in the industry as co-editors for the Securities Industry Association Capital Markets Handbook (“Handbook”), published by Aspen Publishers. thWe designed the Handbook, now in its 6 Edition, to be a handy reference for capital markets/syndicate/investment banking practitioners as well as a useful tool for compliance, regulatory and legal participants in the issuance of new securities. Because it is relevant to the issues on which we wish to comment, we also note that we are co-authors of “Big Bucks for ...