From: Paul Christopherson [Paul.Christopherson@newvernonassociates.com]
Sent: Wednesday, February 11, 2004 11:45 AM
To: rule-comments@sec.gov
Subject: File No SR NASD-2004-020

February 11, 2004

Secretary, SEC

RE: File No. SR-NASD-2004-020

Dear Sirs and Madams:

Regarding NASD Rule 1050, Registration of Research Analysts:--

My firm and I feel quite strongly on one point.  That is, requirements are 
mounting on analysts "associated with NASD member firms", and properly so, in 
our view.

However, these requirements should be made simultaneously with another important 
reform, and that is the elimination of soft dollar payments for third-party 
research.  The continuation of this practice means that research analysts may 
evade professional requirements by just not being associated with a member, and 
still participate fully in the activity.  This amounts to blatantly unfair 
competition for those of us who are so associated.

Thank you for your consideration.

Sincerely,


Paul Christopherson

Paul Christopherson

cc:  Robert Glauber, NASD