[Ameritrade Holding Corporation letterhead]

John S. Markle
Associate General Counsel
Ameritrade Holding Corporation
6940 Columbia Gateway Drive, Suite 200
Columbia, Maryland 21046
443/539-2128 (direct)
443/539-2209 (fax)

March 22, 2004


Mr. Jonathan G. Katz
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549-0901

Re: Proposed Regulation NMS (S7-10-04) — Request to Testify

Dear Mr. Katz:

Ameritrade Holding Corporation ("Ameritrade Holding") would appreciate the opportunity of presenting oral testimony before the Securities and Exchange Commission ("Commission") concerning proposed Regulation NMS.

Ameritrade Holding has a 28-year history of providing financial services to self-directed investors. Ameritrade Holding's wholly-owned subsidiary, Ameritrade, Inc. ("Ameritrade"), acts as a self-directed broker for an investor base of over 3 million client accounts. Ameritrade is an advocate for the retail investor and we believe it is important that we have an opportunity to present our views concerning the Commission's proposals.

We request that we be given the opportunity to present our views at the hearing in New York City, N.Y. on April 21, 2004. Kurt Halvorson, Executive Vice President and Chief Administrative Officer will be presenting on behalf of Ameritrade Holding.

Please contact me at the above noted number if you have any questions.


John S. Markle
Associate General Counsel