Subject: file # 10-101
Date:    7/9/98 10:11 AM
     
     
Jonathan G Katz,
Secretary,
Securities and Exchange Commission
450 Fifth Street NW
Washington DC
20549
     
Dear Sir:
     
I am writing to comment on the application for exemption from 
registration by the Tradepoint Stock Exchange.
     
I am an Assistant Professor at the Institute of Finance and 
Accounting at the London Business School. I have long had a research 
interest in the area of market microstructure and market design. I 
have also had a close interest in the development of the Tradepoint 
Exchange, and have served as the Chairman of its Market Advisory 
Panel, an independent body of practitioners and academics set up to 
advise the Exchange.
     
I am writing in support of Tradepoint's application. In my 
view, Tradepoint offers a form of access to the London equity market 
which greatly widens the choices open to investors. The main 
alternative to Tradepoint is of course the London Stock Exchange 
(LSE). Despite the recent introduction of its electronic order book, 
the LSE is essentially still a dealer based market. Most trades are 
done with a broker-dealer who is likely to be acting as the 
counter-party to the trade.
     
Tradepoint offers investors the opportunity to deal directly with the 
rest of the market, inputting their own orders, and managing them as 
they will over time. It is also a transparent market where all users 
of the system have access to exactly the same information at exactly 
the same time.
     
The existence of the Tradepoint market therefore represents a great 
widening in choice of trading strategy and trading environment for 
the investor. It is to be welcomed on that count alone. It also sets 
ver high standards for transparency and openness, something which is 
likely to be particularly welcome to US investors who find the 
degree of disclosure on the LSE rather limited.
     
I believe there are also wider advantages to be gained from the 
existence of competition between exchanges and trading 
mechanisms in encouraging a better service for customers, 
particularly in the context of the dominating market share in the 
trading of UK equities held by the LSE. These are advantages which 
the SEC has recognized in its policy making in the domestic US 
market.
     
The Tradepoint Exchange has a relatively small market share. It 
would not be appropriate to subject it to the full bureaucratic 
weight of registration given that the objectives of investor 
protection can be adequately achieved through other means.
     
I therefore welcome a sensible solution which will allow investors in 
the US to access the London equity market directly, and also helps 
foster competition in the London equity market.
     
Yours sincerely,
     
Anthony Neuberger
     
Anthony Neuberger
Institute of Finance and Accounting
London Business School
Sussex Place
London NW1 4SA
     
Tel: (44) (0) 171 262 5050 ext 3360
Fax: (44) (0) 171 724 3317