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Comment Letters on SEC Proposed Rules

Comment Letters on SRO Proposed Rules

Legislative Update

NASD-99-53
Proposal: Rel. #: File #: Comments Due: # Letters to Date:
Enhance quotation montage by creating a new venue for the display of trading interest, called the Nasdaq Order Display Facility. 34-42166 NASD-99-53 1/11/00 extended from 12/27/99 33

Letters Released June 12-23: Date: Position:
Granite Financial Group, Inc. 6/26/00 The managing director of this financial group is firmly opposed to the proposed rule changes. The primary problem, he states, is the elimination of the no-decrementation feature and the market maker's ability to see all orders and their size. This eliminates a market maker's ability to achieve a best price execution for customers.
Archipelago L.L.C. 6/19/00 The CEO of this company states that the proposal should be rejected because it would introduce Nasdaq into the order execution business and create conflicts of interest that would harm investors. He adds, however, that the conflicts would fade away if Nasdaq were entirely independent of NASD.
Net2000 Communications 6/2/00 Robert Bannon is clarifying remarks attributed to him in an earlier comment letter. He would encourage the approval of SuperMontage, although he would like to see improvement to the basic foundation after its approval.

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