From: Steve Dalton [SDalton@netfusiondesign.com]
Sent: Thursday, August 09, 2001 7:17 AM
To: 'rule-comments@sec.gov'
Subject: Sub Penny trading

Having made the necessary conversions, we need to simply recognize the standard adopted in April and stop tinkering with it.  The rule that establish $.01 as the minimum standard trading increment affects everyone equally and is understandable to the customers.  I feel that when we attempt to establish a value on any given security at an increment lower than what people are willing to stoop down and pick up in a parking lot, we start to trivialize the valuation, whether it is a trade for 100 shares or one million shares.  We agreed to adopt a standard on April 9th, and we are already discussing changes to it, four short months later.  Aren’t we supposed to be explaining to our clients the benefits of a long term course of action?  Then lets take that advice ourselves and leave the increment set at pocket change.

 

Steve Dalton

Dalton Strategic Investment Services, Inc.