To:Securities and Exchange Commission
450 Fifth Street, N. W.
Washington D.C. 20549-0609
From:George Tumas
Managing Director
Banc of America Securities

In response to your invitation for comments on revised decimal implementation schedules (File No. 4-430) we are providing the following:

1. Is it feasible to begin Dual Pricing by September 4, 2000? If it is feasible, should trading in all exchange-listed securities be in nickel or penny increments? If it is not feasible to begin Dual Pricing by September 4, 2000, why not?

It is feasible to begin dual pricing by September 4, 2000. Nickel increments would be best as this might allow the industry to experience potential volume increases at a slower pace.

2. What, if any, systems changes or other steps would be necessary to implement Dual Pricing by this September 4, 2000 deadline? What type of changes would need to be made to the systems of securities firms, investment companies, and vendors? What would be the impact on systems capacity? In light of your answers to the foregoing questions, what changes would need to be made to the current decimals testing schedule?

We would need to modify the floor input and break processing systems. Transaction rates would increase. We estimate the increase in transaction volumes would be about 60% for the trade entry systems and about 20% for all other system loads. We would want to have the opportunity to complete additional testing in July and August with the industry.

3. Is the risk of customer confusion because of Dual Pricing significant, and if so, how should it be addressed?

We expect that our traders, clearing clients, and prime brokers would realize most of the confusion associated with dual pricing. The brokers and traders will be required to keep track of pricing requirements by security. Errors made as a result of dual pricing could impact customer confidence.

4. If commenters believe that implementing Dual Pricing by September 4, 2000 is not feasible, what date(s) is(are) feasible to implement Dual Pricing? Commenters should include a discussion of the systems changes and testing schedules that would be needed for their alternative implementation date(s).

N/A - Dual pricing is feasible.

5. In addition, if commenters believe that implementing Dual Pricing by September 4, 2000 is not feasible, is the alternative Decimals Pilot proposal feasible or preferable? If commenters believe that the Decimals Pilot is feasible, what, if any, systems changes or other steps would be necessary to facilitate this schedule? In particular, what changes would need to be made to the current decimals testing schedule? What type of changes would need to be made to the systems of securities firms, investment companies, and vendors? What would be the impact on systems capacity? Is there a risk of customer confusion, and if so, how should it be addressed?

N/A - Dual pricing is feasible.

6. If commenters believe that the Decimals Pilot is not feasible, what alternative would expedite the implementation of decimal pricing in exchange-listed and Nasdaq securities? Commenters should include a discussion of the systems changes and testing schedules that would be needed for their alternative, including implementation date(s).

Dual pricing is feasible. It would also require that we perform two (or more) conversions which will double the cost and resource requirement for the total effort.

7. Commenters are requested to offer specific views on the optimal schedule for implementing decimal pricing in options based on exchange-listed and Nasdaq stocks subject to decimal pricing.

The price for an option should change to decimal when the underlying security price changes to decimal.