January 5, 2001
Mr. Jonathan Katz
Securities and Exchange Commission
450 Fifth Street
Washington, DC 20549-0609
Re: File No. SR-DTC-00-10 - Combination of the DTC's TradeSuite Institutional Trade Processing Services With Thomson-Financial ESG's Institutional Trade Processing Services
Dear Mr. Katz:
The Asset Managers Forum ("AMF"), an independent trade group which is affiliated with The Bond Market Association, appreciates the opportunity to submit this comment letter regarding the proposed joint venture between The Depository Trust & Clearing Corporation (DTCC) and Thomson Financial. The AMF represents the interests of Wall Street's asset managers or buyside firms with regard to their securities processing activities. The AMF currently has over 40 member firms, with combined NAV relating to assets under management in excess of $6 trillion.
As the industry faces increasing trade volumes, greater settlement exposure and the SEC's challenge to reduce the settlement cycle, we feel that the development of straight-through processing solutions for U.S. and cross-border trades is essential. By leveraging their complementary strengths, DTCC and Thomson Financial will be uniquely positioned to develop a high quality trade management platform for participants in the securities markets and play a vital role in the overall STP model.
While AMF supports the development of a centralized industry matching utility, we consider interoperability and competition between service providers to be critical. We urge the Commission to take steps to ensure that the current unique position of DTCC in the securities settlement area will be used to facilitate appropriate competition between and among the proposed Global Joint Venture and other entities, including GSTP AG. In particular, we feel that all potential providers of such services must have direct access to DTCC's settlement facilities, including service, support and technical assistance, on terms no less favorable than the proposed Global Joint Venture. The AMF stands strongly behind achieving efficiencies with regard to the processing of securities transactions as the investment community develops its T+1 game plan.
The AMF wishes to thank the Commission for this opportunity to express its views. We are available to discuss any of the comments in this letter with the Commission or its staff. If we can be of further assistance to the Commission in this regard, please do not hesitate to contact the undersigned or Ken Juster, Director of the AMF, at 212-440-9471.
Fischer Francis Trees & Watts
Chairman - AMF
| s/Gary Koenig|
Dresdner RCM Global Investors
Vice Chairman - AMF