July 20, 2006
Nancy M. Morris, Esq.
Secretary
United States Securities and Exchange Commission
Re: File No. NYSE 2006-46
Dear Ms. Morris:
I am writing the Commission in response to the NYSE proposal to revise the transaction fees of the New York Stock Exhchange. I strongly believe the commission should not approve this proposal.
I have been an independent floor broker on the NYSE since 1979. I believe that I represent the true independent broker. I execute trades for a wide range of customers:sell-side, buy-side, non-member broker dealers. I have been able to adapt to all types of market conditions over the years( some slow times in the early eighties, the crash in 1987, the crash in 1990, and the bursting of the technology bubble in 2000, just to name a few). However, the one event that will put me out of business is this fee proposal from the NYSE.
I received a comparison from the NYSE of my current transaction fees to those under this new proposal. My transaction fees will rise 1110.2% under the new proposal. I just want to repeat this number. 1110.2%. This is an outrage. I can't believe that the New York Stock Exchange's intent is to make a profit by raising the independents' fees by these unprecedented percentages especially when the largest brokerage firms' fees are rising a maximum of 25%.
I implore you not to approve this new fee structure proposal. I have every intention of continuing to provide quality execution services to my clients. I do not want to be forced out by an apparently arbitrary and unevenly applied new fee structure.
Respectfully submitted,
Allan Gershowitz, President
Allan Gershowitz Securities Corp.