Mr. Jonathan G. Katz
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549
RE: File No. S7-12-98
Dear Mr. Katz,
We are submitting this comment letter on proposed Regulation ATS to express our concern regarding this new proposal. As an institutional money manager, we depend on quick and anonymous trading systems to execute many of our orders. The past changes from the SEC regarding public display of orders has been horrendous for institutions and principle market markers alike, and has rendered the ability to seamlessly trade blocks of stock difficult if not impossible on small, less liquid names.
This new proposal ,we believe, will make the ability to trade even more difficult. The volatility of individual stocks will increase, and the only individuals who would benefit from this and prior public display regulation changes are the electronic day traders.
I would urge careful thought as to the consequences of this implementation.
Thank you for your consideration.
J. Eric Vaughan
The Honorable Arthur Levitt, Chairman
The Honorable Norman S. Johnson, Commissioner
The Honorable Isaac C. Hunt, Jr., Commissioner
The Honorable Laura S. Unger, Commissioner
The Honorable Paul R. Carey, Commissioner
Richard R. Lindsay, Director, Division of Market Regulation
Erik R. Sirri, Chief Economist
Annette Nazareth, Acting Director, Division of Investment Management