August 10, 2007
Nancy M. Morris
U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549-1090
Re: File Nos. 4-533 and 4-534
Dear Ms. Morris:
SVB Financial Group is pleased to provide comments in connection with the two plans before the Commission regarding the selection and reservation of trading symbols. SVB Financial Group supports the proposed plan submitted by NASDAQ and several other exchanges (the “Five Characters Plan”) as it believes it will: (i) enhance competition among markets by putting all exchanges on a fair and level playing field, (ii) reduce the potential for investor confusion by allowing a fair framework for symbol portability, and (iii) promote the flexibility of listing options for issuers, which would ultimately benefit shareholders and public investors.
We believe all issuers, no matter where they are listed, should have the capability of trading under a 3-letter or fewer symbol. Public companies and investors should be afforded the best trading platform, low fees and a comprehensive set of services. They should not be subjected to restrictions with regard to symbol use that are not equally applied to all exchanges.
Accordingly, we believe the Five Characters Plan would provide greater choice for public companies and less confusion for investors, and SVB Financial Group supports the approval of this plan by the Commission. We fully support a symbology process that is fair and transparent, and focuses on the needs of issuers and public investors.
SVB Financial Group
By: Harry Kellogg
Its: Vice Chairman SVB