Author: "Robert Adriaanse" at OPC Date: 01/05/2001 2:34 PM Normal TO: KatzJ at 03SEC TO: RULE-COMMENTS at 03SEC Subject: SuperMontage proposal (SR-NASD-99-53) ------------------------------- Message Contents Dear Sir: I understand that the SEC is meeting next Wednesday, January 10th, to vote on the SuperMontage proposal. I believe that the passage of this proposal would be harmful to investors, institutional as well as retail, for several reasons. Three of those reasons are: -The "preferencing" aspect of SuperMontage should be eliminated. Preferencing will allow market makers to trade ahead of and around earlier- arriving investors' orders. Investors will reveal valuable information without receiving a corresponding benefit. -The "price/size/time" algorithm should be eliminated. This algorithm will allow larger-sized orders to trade ahead of investors who were the first to quote at the best price. It will reduce investors' incentives to post orders that reduce spreads. -The SuperMontage algorithm should be neutral with respect to ECN access fees. SuperMontage also contains an algorithm that discriminates against investors who use ECNs. This algorithm always will give market makers' orders priority over investor orders entered on ECNs. I would appreciate if you would take these points into consideration when deciding on the SuperMontage Proposal. Sincerely, Robert Adriaanse Head Trader, Global Equities DuPont Capital Management robert.adriaanse@usa.dupont.com