The Honorable Arthur Levitt, Jr.


U.S. Securities and Exchange Commission

450 Fifth Street, N.W.

Washington D.C. 20549

April 3, 1998

Dear Mr. Levitt:

I write to you over my concern with a feature of the POSIT trading system that has significant disadvantages for our clients, including many retail mutual fund investors.

POSIT currently allows participating institutions to exclude brokers from possible trades. Columbus Circle Investors, although an institutional investor that uses the system directly, uses brokers to represent us in this system. This broker representation allows us to benefit from their commitment of capital to work an order and reduce ticket charges to our clients by booking only one ticket per execution. On several occasions, however, including twice in the last month, we have been excluded from trades because our broker matched with an institution that forbid trading with a broker. This exception hurts our trade execution.

I’m not sure if the SEC condones this feature of the POSIT system, but I feel it should be changed to allow all participants to trade with the best possible price. I would be happy to discuss this further with your staff at your convenience.

Thank you for your attention to this matter.


Christopher B. Burnham

President and Chief Executive Officer