January 19, 2005
As the lessor of a seat on the New York Stock Exchange I am writing concerning the Regulation NMS proposal.
One of the alternative proposals in this File, the Consolidated Limited Book Order, CLOB, raises particular concerns because of the costs and effects it may have on US
securities markets. It is also an operational unknown. The CLOB has been previously rejected by the SEC and Congress because of these concerns. It seems to me that the auction market system we have in effect has served this country and all of the investing public well, from individuals to large institutions. This is not to say that greater usage of electronics has a place in this system to speed certain trades. For these reasons I support the Best Price proposal as well as the NYSEs Hybrid Market proposal. The latter proposal combines the best of both market systems, the auction and electronic, and provides a measured, but significant, step forward. It does not carry with it the potential for disruption of the US securities markets that a totally new system, such as the CLOB,has. The CLOB should be rejected again as it was earlier.
I thank the SEC for providing the opportunity to comment on the revised NMS Regulation proposal.
William T. Baker, Jr.