August 9, 2005
Re: Comments regarding File Number S7-06-05
Notice of an Application of the New York Stock Exchange, Inc. for an Exemption Pursuant to Section 36 of the Securities and Exchange Act of 1934 dated July 8, 2005.
I would like to comment on the proposed application, referred to above. I am a retired investor who has a significant portion of my assets invested in fixed income securities in an attempt to maintain a diversified portfolio for the purpose of generating income. While I am not in a position to respond to all the issues you have raised there are a couple that I would like to comment on because I believe they will impact the way in which I manage my portfolio.
I believe that the exemption would increase competition in the public debt markets for the small investor primarily due to the increased price transparency afforded by the Exchange. Ever since I can remember the only place bond prices were published were in the Wall Street Journal and other newspapers and they were prices of bonds traded on the NYSE. These prices were for odd lots, as small as one bond and like stocks these prices were ex- commission. Today, these price tables have disappeared from view. While I realize that the debt market is primarily an institutional market I believe that there should be a place for the small investor to easily get price information.
Under current practices a small investor is required to have accounts with multiple broker/dealers if they want to do any price comparisons shopping for small lots of debt securities. A few broker/dealers do maintain price information for their inventory on web sites if you have an account. If you wish to purchase or sell a few bonds you have to rely on a broker and trust that you are getting a fair price.
By allowing issues to be traded on the Exchange without being listed will greatly increase access for small investors. This exemption will help level the playing field for the small investor and permit many more issues to be traded at the NYSEs market.
I strongly support the NYSEs position and believe that they should receive the S.E.C.s full support in bringing the benefits of a transparent debt market to the individual investor without being constrained by regulatory burdens.