June 26, 2011
A Message from Issuer Advisory Group, LLC
Corporate America's Leading Issuer Advocate and Market Expert
Hi Robert and David,
IFirst, congratulations on expanding the circuit breakers in individual stocks to all US listed stocks. As you know, we have been and remain big fans of your efforts in this regard. Our sole concern, that not all stocks (such as Dendreon who fell precipitously) were not covered, has now been alleviated. We also support your efforts with respect to LULD and are anxious to see that become a reality.
We have noted with great interest the responses to the NYSE's filing with respect to permissible issuer services. Interestingly, all thirteen responses stand against this proposal and appear to be an orchestrated response from smaller practitioners. Issuers, on the other hand, are strongly against the proposal for very different reasons. We are still collecting their feedback and will be submitting a comment letter later this week. I wanted to give you a heads up that it is likely that we will call for a complete reengineering of the listing fee structure thereby eliminating this controversy.
As always, we appreciate what you do and stand prepared to help in any way you so require.
tks/PJH
Patrick J. Healy, CEO
Issuer Advisory Group