From: Fung, Nicholas
Sent: Wednesday, April 21, 2004 4:29 PM
Subject: S7-13-04:

The STP initiative for T+0 RVP/DVP confirmation processing overlooks some of the issues faced by small to mid sized Broker/Dealers and Investment Managers that do not wish to incur the added costs of subscribing to &/or interfacing with such services at Thomson AUTEX & ALERT for customer N&A information and customer trade allocation processing. By nature, a great deal of the RVP/DVP orders are considered to be Block transactions and are worked by an institutional desk, sometimes throughout the day, before full &/or partial execution status is achieved. The execution must then be conveyed by e-mail, fax &/or phone to the Investment Manager for him to determine the customer allocation that is then submitted in a similar fashion to the Broker/Dealer for processing. In many instances, the customer breakdown may include several new accounts, the information for which must then be obtained from the Investment Manager and the account established in the Broker's system prior to the billing for generation of the ID Confirm. The timing and volume processing requirements may in many instances, delay the Broker customer billing until T+1.

Free Funds letters are in most cases, not sent until T+1.
An alternative processing suggestion, assuming participation of both parties &/or their agents in the Omgeo Confirmation facility is to:

Sender: Nicholas Fung, Independent Brokerage Consultant