Subject: File No. S7-06-05
From: Denis P. Kelleher
Affiliation: CEO, Wall Street Access

August 9, 2005

Wall Street Access is an NYSE member firm that serves institutional and high-net worth individual investors. Founded in 1981, the firm offers its investors independent research and specialized execution services. Currently, the firms research effort focuses on merger activity, healthcare, regulatory analysis and the energy-utility sector. Wall Street Access is not a market-maker and does not offer general investment banking services. The firm is a member of the NASD, the ISE and SIPC and clears its trades through Pershing, L.L.C.
Over the past several years, our firm has attempted to improve the price and quote transparency of the corporate debt markets. We do not carry bond inventory and must seek out market information from market-makers when we are given corporate bond orders by our customers. The process is time-consuming and frustrating since the lack of a central marketplace makes it difficult for us to determine that our customers are getting the best prices for their orders. On June 20, 2003, we wrote a letter to the NYSE suggesting that the NYSE amend its rules to require listed companies whose stocks are eligible for trading to list their publicly traded debt securities on the NYSEs Automated Bond Trading System. In response to our suggestions, the NYSE explained its need to seek exemptions, pursuant to Section 36 of the 1934 Act, from the current SEC regulatory policy. This File No. S7-06-05 proposal is the end result of the NYSEs effort and our firm strongly endorses and supports the proposed rule changes.
While the NASDs recently improved coverage of the corporate bond market through the TRACE system has helped us serve our customers, the TRACE network does not provide current bid-asked quote data and the prices from actual trades are delayed before being displayed to the marketplace. By contrast, the NYSE proposal would offer a much more transparent system of quotes and prices that will speed up the execution process and enhance investor confidence that the trades will be executed at the best prices. We see no investor downside to the adoption of this proposal which will improve corporate bond market transparency with no loss of corporate disclosure only debt securities registered under the 1933 Act by issuers subject to Section 12b equity registration would be allowed for trading under the proposed exemption. Accordingly, Wall Street Access supports the adoption of the proposed exemption and looks forward to serving its corporate bond trading customers under the revised NYSE system as soon as the new structure can be implemented.