From: Mike Ianni [ianni@rogers.com]
Sent: Friday, September 12, 2003 1:28 PM
To: rule-comments@sec.gov
Subject: SR-BSE-2002-15

 
One concern no one seems to be talking about are the penny increments.  
Initially, these penny increments will not likely be displayed via OPRA.  
However, as more Exchanges adopt similar PIP rules (ISE has already submitted 
a rule to the SEC), penny increments will likely be forced upon OPRA and all 
data providers.  This increased traffic could easily be 5-10 times what it is 
today.  This will create many problems for not only data providers but for all 
end users (traders/market makers) of the data as they must also increase 
bandwidth in order to receive the same number of quotes as previously.
 
I suggest that the SEC limit all PIP's to standard ticks (.05 and .10).  It 
would not make sense to approve penny increments if you know that OPRA can't 
handle this increased traffic for all option Exchanges. 
 
 
Mike Ianni
Private Investor