From: Mitchell Feuer [mitchell.feuer@rfgdc.com]
Sent: Friday, March 26, 2004 3:48 PM
To: 'rule-comments@sec.gov'
Cc: Sapna Patel (E-mail)
Subject: S7-10-04 - Request to Testify:

Summary of intended testimony:

On behalf of the Financial Services Roundtable, I would like to provide the
following summary of the testimony the Roundtable hopes to provide at the public
hearing in New York on April 21.  The Roundtable expects its testimony would be
deliverd by Richard Thornbugh, Chief Risk Officer of Credit Suisse Group and
member of the CSFB operating committee.

*	In general, the Roundtable supports the introduction of greater competition
and flexibility in U.S. market structure.

*	On the issue of access, the Roundtable believes there should be more
flexibility and greater scope for the marketplace to determine how linkages work
and the technology used.

*	The "soft linkages" model implemented by the NASD Display Facility should be
considered as an alternative to the "hard linkages" model.  It allows the
marketplace a greater role to determine technology.

*	The governance of ITS should include more of a role for market participants.
More consideration should be given to the "veto" each exchange has over ITS
changes and to a voting or advisory role for market participants beyond the
exchanges.

*	The Roundtable supports reform of the "trade through" rule in ITS.  The
current "one size fits all" approach may not serve the marketplace well.  Many
market participants would appreciate a greater ability to prioritize factors
such as speed and size over "best price."  At the same time, small retail orders
must continue to receive the protection of best execution.

*	With regard to the operation of exchanges, the Roundtable believes there
should be a greater role for competition.

The Roundtable believes that consideration should be given to allowing the
marketplace greater ability to determine whether actively traded stocks and
small 	orders are better suited to a matching process than to specialist/market
maker roles.