From: James Angel [mailto:ANGELJ@georgetown.edu]
Sent: Thursday, April 05, 2001 2:30 PM
To: rule-comments@sec.gov
Subject: File Number S7-03-01


Dear Mr. Katz:

Thank you for the opportunity to comment on the proposed rule "Proposed Rule Changes of Self-Regulatory Organizations," file number S7-03-01.  I think that this proposal is a great step forward that will eliminate unnecessary costs for the SEC as well as for the SROs.   This will also create a more dynamic and innovative securities market by allowing SROs to be more flexible.  As the proposing release points out, foreign entities that compete with our domestic SROs do not face the burden of the current rulemaking process. 

If anything, I would suggest that the Commission  should be even more bold in exercising its broad exemptive authority under section 36 of the Securities Exchange Act.   I suggest moving toward a blanket exemption for all SRO rule filings, with the provision that the SEC could abrogate any rule at any time. 

However, there is another improvement that you can make in the process.  Some SROs do not make their rule books available to the public on their web sites.  In the spirit of transparency and public participation, I urge that the Commission, as part of the final rule, require SROs to post their rulebooks on their web sites.  Many foreign stock exchanges already do this, and it is shocking that some U.S. markets do not.  It is sometimes very difficult for a scholar to find out exactly what the rules are on certain markets. 

Similarly, I suggest that the Commission itself make sure that all SRO filings, such as comments on Commission proposals, are available via the web, either on the SEC's own site or on the SRO sites.  It is still unduly time consuming to find many of these filings. 

The Commission can also create similar improvements in the process for approving new financial innovations such as new exchange traded funds.  Right now the regulatory approval process for such roducts is extraordinarily slow and cumbersome, with little apparent benefit to the consumer.   This process needs to be speeded up and simplified as dramatically as this proposal improves SRO rule filings. 



Sincerely,


James J. Angel, Ph.D.
Associate Professor of Finance
McDonough School of Business
Georgetown University
Room G4 Old North
Washington, DC 20057  USA

angelj@georgetown.edu