110 Fieldcrest Ave.
Raritan Center 1
Edison, NJ 08818
Mr. Jonathan G. Katz, Secretary
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549-0609
Dear Secretary Katz:
I am writing this letter to voice my concerns about the upcoming rule change proposal that Nasdaq is considering. The specific rule that I am referring to is the Super Soes Reserve Size Display Requirement and Refresh Increment change (SR-NASD-2001-66) that is now being discussed. I have been an active securities trader for several years now, and I am extremely concerned that this proposed rule change will greatly hinder the integrity of the securities market, especially when it comes to the interests of the smaller investor.
The ideal goal of Nasdaq, as well as any public trading marketplace, is to establish a fair and equitable market, where traders, both institutional and individual alike, can be assured that they are getting the best prices for their transactions. One of the best ways to both achieve and enforce this environment is through market transparency, something that has long been a goal of the S.E.C. This new proposal is in direct contrast to that goal. Market makers already hold a distinct advantage over the individual investor in the Nasdaq marketplace, and now they wish to be able to disguise their true order size even further, through the use of 100 share quotes that do not have to be updated. This rule proposal seems as its goal to only reduce or eliminate the limited transparency that currently exists. In fact, it seems to be in direct contrast with the goals and ideals of what the S.E.C. has in mind when it dictates that it wants a "fair and equitable market," where full transparency is something that is desired, not hindered.
Another issue is that market makers no longer will have to update to 1000 shares after a SOES execution. Before Super Soes, market makers were able to "hold the offer" or "hold the bid" in stocks, so to speak, without really selling or buying any significant amount of stock. The pupose of doing this was clearly nothing more than the blantant and outright manipulation of the market for the market makers own financial benefit. It would be quite simple for a market maker to kill any sort of momentum in a stock by simply giving out 100 shares at a time without ever updating to 1000 shares, or changing his price quoted. This sort of activity, even thought blatantly illegal, was rampant in the days before Super Soes, and only after the introduction of Super Soes, has this activity finally been halted. It seems absurd to propose a rule change that serves only to allow increased manipulation of the markets by the market makers, with no benefit in any way to the individual investor.
In summary, I believe that this rule change will only serve to increase the market makers' ability to manipulate the markets at the cost of the individual investor. Furthermore, transparency, which has been a long time goal of the S.E.C., will greatly be reduced. The S.E.C. has long desired that the markets work on a "level playing field" for both the large and small investor alike. This new rule proposal seems to contradict these goals completely and entirely.
Thank you for your time, and if you wish to discuss this further, you can contact me at either 732-744-9191, or firstname.lastname@example.org.
John Chinnock, M.B.A.