Subject: File No. 4-430

Date:    05/03/2000 3:34 PM
     
     
ILX Systems
111 Fulton Street
New York, NY 10038
     
                                1. Is it feasible to begin Dual Pricing by
September 4, 2000? If it is feasible, should trading in all exchange-listed 
securities be in nickel or penny increments? If it is not feasible to begin 
Dual Pricing by September 4, 2000, why not?
     
                                Implementing dual pricing is feasible by
September 4, 2000, provided that prices for the same securities are not 
quoted in both decimals and fractions on different exchanges. ILX would 
prefer going to penny increments immediately. 
     
                                2. What, if any, systems changes or other
steps would be necessary to implement Dual Pricing by this September 4, 2000 
deadline? What type of changes would need to be made to the systems of 
securities firms, investment companies, and vendors? What would be the 
impact on systems capacity? In light of your answers to the foregoing 
questions, what changes would need to be made to the current decimals 
testing schedule? 
     
                                ILX has already expanded our central system
capacity and is prepared to proceed right now. Users at securities firms and 
investment companies who have not as yet upgraded their own system capacity 
may have to do so. ILX has developed a proprietary throughput optimizer, ILX 
Turbo, which mitigates capacity issues for its clients.
     
                                3. Is the risk of customer confusion because
of Dual Pricing significant, and if so, how should it be addressed? 
     
                                Customer confusion should be minimal as
indices, Bulletin Board securities and foreign issues are all currently 
quoted in decimal format.
     
                                4. If commenters believe that implementing
Dual Pricing by September 4, 2000 is not feasible, what date(s) is(are) 
feasible to implement Dual Pricing? Commenters should include a discussion 
of the systems changes and testing schedules that would be needed for their 
alternative implementation date(s). 
     
                                Dual pricing is feasible by September 4,
2000 (See answers above).
     
                                5. In addition, if commenters believe that
implementing Dual Pricing by September 4, 2000 is not feasible, is the 
alternative Decimals Pilot proposal feasible or preferable? If commenters 
believe that the Decimals Pilot is feasible, what, if any, systems changes 
or other steps would be necessary to facilitate this schedule? In 
particular, what changes would need to be made to the current decimals 
testing schedule? What type of changes would need to be made to the systems 
of securities firms, investment companies, and vendors? What would be the 
impact on systems capacity? Is there a risk of customer confusion, and if 
so, how should it be addressed? 
     
                                No changes are necessary to the testing
schedule.  (See answers above.)
     
                                6. If commenters believe that the Decimals
Pilot is not feasible, what alternative would expedite the implementation of 
decimal pricing in exchange-listed and Nasdaq securities? Commenters should 
include a discussion of the systems changes and testing schedules that would 
be needed for their alternative, including implementation date(s). 
     
                                 Dual pricing is feasible by September 4,
2000 (See answers above). 
     
                                7. Commenters are requested to offer
specific views on the optimal schedule for implementing decimal pricing in 
options based on exchange-listed and Nasdaq stocks subject to decimal 
pricing. 
     
                                No changes are necessary to the testing
schedule.