119 West 57th Street, New York, NY 10019
(212) 489-7527 (800) 223-2281 fax (212) 489-1626
July 30, 2003
Mr. Jonathan Katz
United States Securities and Exchange Commission
450 5th Street, N.W.
Washington, DC 20549
Re: Rule-Making Proposal No. 4-483
Dear Mr. Katz:
Sometimes I liken the regulatory process to keeping my country house free of mice. The tiniest crack affords entry to the critters. Once inside they breed and...well, you know the rest. On Wall Street every little chink in our perimeter allows rats into our house. Rodents have a facility for crawling through small cracks and seeking out places of darkness. Shine a bright light on them and they are soon gone. This in effect, is what Mr. Nelson has proposed in his lengthy petition.
You may well ask about the writer of this banal prose. I have been in the investment business since the mid 1960s. My firm, a dual registrant (both a broker dealer and an investment advisor) was established in 1984. We spend a great deal of our time looking for value in Pink Sheets, Bulletin Board and other illiquid and inefficient regions of the markets on behalf of our clients. In addition to the pursuit of riches, I have served on the District 10 Committee of the NASD and currently sit on the National Adjudicatory Council. Enclosed is a summary of our firm's activities and background information on our principals.
I strongly concur with most of the points made in the Proposal and urge the commission to not only review the matters set forth but also matters relating to the proposed dismemberment of the Bulletin Board. It is vital that full daylight exist as a result of required public filings, but also in public access to trading prices and volume in the markets themselves.
Rather than go on at length I will be delighted to visit and discuss these issues with you or any members of your staff.
Thank you in advance for your consideration. Wishing you continued fortitude in your difficult task.
Philip V. Oppenheimer