Subject: File No. SR-NASD-2005-022
From: Gail M Dudack, CMT
Affiliation: Director of Research; Chief Investment Strategist; Managing Director; SunGard Institutional Brokerage Inc.

March 22, 2005

Technical analysis is important to the overall investment process since it adds idea generation and risk control to any good investment plan used by both public and private investors. But like any analytical process, it requires study, discipline and expertise to do it well. The CMT designation, much like the CFA program, is a rigorous 3 year/3 part exam for technical analysis. The Market Technicians Association has worked diligently over the years and has employed testing professionals to ensure that the CMT exams will guarantee that those that pass the three year exam process to get a CMT will have the knowledge and expertise to do their analysis professionally and well. I believe the CMT designation, like the CFA requirement, should be a substitution for the series 86 examination. Moreover, since the 86 is geared totally toward fundamental analysis of individual companies, it would provide no guarantee that a technical analyst is proficient in their profession. I support passage of this proposal.