Securities Regulatory Update Online wsb.com Library
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Comment Letters on SEC Proposed Rules

Comment Letters on SRO Proposed Rules

Legislative Update

NYSE-99-48
Proposal: Rel. #: File #: Comments Due: # Letters to Date:
Concept release on market fragmentation. 34-42450; 34-42723 NYSE-99-48 5/12/00 extended from 3/20/00 82

Letters Released June 12-23: Date: Position:
T. Rowe Price Assocs., Inc. 6/20/00 T. Rowe Price feels that any SEC solution should eliminate the negative effects of the internalization of order flow. Firms should be rewarded for competing on price to attract order flow. Instead of endorsing any one method, T. Rowe Price suggests that price and time priority should be an element of any SEC solution.
SunGard Trading Systems, Inc. 6/6/00 SunGard believes that instead of a centralized "inflexible" system such as CLOB or Universal Switch, the SEC should continue to encourage innovation through service competition and price transparency.
CIBC World Markets Corp. 5/26/00 CIBC believes the SEC should advocate a varied market structure that could be accessed by any participant, linked by market makers, dealers and specialists and their respective duties of best execution, as opposed to a single structure based upon a mandated linkage predicated on time and price priority of certain orders.
3 letters by individuals 3/30–5/18/00 These individuals submitted comment letters with respect to this regulation.

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