TJM Investments, LLC
February 12, 2003
Mr. Jonathan G. Katz
Re: SR-BSE-2002-15, Boston Stock Exchange, Inc. Filing to Establish Trading Rules for the Boston Options Exchange Facility
Dear Mr. Katz:
TJM Investments, LLC and its subsidiaries ("TJM") appreciate the opportunity to submit this endorsement for the approval of the Boston Options Exchange ("BOX"). TJM is a broker-dealer registered with the Securities and Exchange Commission, and it is a member of both the NASD and of the International Securities Exchange (electronic access member). TJM and its principals are registered with the Commodity Futures Trading Commission as a Commodity Trading Advisor and an independent Introducing Broker, and also are members of the National Futures Association and Chicago Mercantile Exchange. Our core service is trade execution for institutional market participants. In addition, TJM Systems, LLC provides participants with its direct market access system, TJM AccessTM.
We believe that the creation of this new electronic options trading facility, with its innovative market model, will provide a welcome alternative to the existing exchange structures. BOX will be more transparent, faster, fairer, and cheaper for participants. We are particularly supportive of a market structure where orders from all types of market participants will interact directly with each other on a price/time priority basis. Our support is based on our understanding that any order, public customer or broker-dealer, may provide or take liquidity. All orders are live and available to all participants with no limitations on the ability of professional or broker-dealer orders to access the order book. We also applaud the lack of barriers to entry, specifically no equity investment requirement. Please know that our 2003 business plan and budget calls for our joining the BOX and offering access to participants in search of more efficient markets.
In light of the foregoing, TJM strongly encourages the Commission to approve the BOX.