July 19, 2005
I HAVE 40 YEARS OF EXPERIENCE WORKING ON WALL STREET IN
THE CAPACITY OF OPERATIONS AND COMPLIANCE PARTNER AT A SELF CLEARING FIRM. I HAVE WORKED ON THE FLOOR OF THE NYSE AND
HAVE BEEN A CHARTER MEMBER OF BOTH THE DEPOSITORY TRUST
COMPANY AND THE NATIONAL SECURITIES CLEARING CORP.THESE
ORGANIZATIONS HAVE SINCE MERGED. IN ADDITION I HAVE WORKED
ON SEVERAL POLICY COMMITTEES CONCERNING SUCH TOPICS AS
SETTLEMENT DATE REGULATIONS AND OTHER REGULATIONS CONVERING
CLEARANCE AND COMPLIANCE ON WALL STREET.
FOR THE LAST 5 YEARS I HAVE BEEN IN CONTACT WITH THE NYSE
AND HAVE DISCUSSED OUR FIRMS DESIRE TO HAVE MORE CORPORATE
BOND TRADING AVAILABLE TO IT ON THE NYSE. SINCE MOST OF THE
BONDS THAT DO TRADE TRADE OTC WE HAVE NEVER BEEN ABLE TO
GET A REAL CLEAR PICTURE OF THE MARKET. EVEN SYSTEMS SUCH
AS TRACE DO NOT PROVIDE SUCH UP TO THE MINUTE INFORMATION.
THE SITUATION EXISTS WHERE THE LARGE CORPORATE BOND DESKS
CONTROL THE PRICING OF THESE SECURITIES. A LISTING ON AN
EXCHANGE WOULD GIVE MORE VISABILITY TO THE TRUE MARKETS ON
SUCH SECURITIES I FEEL. THE SIZE AND BID AND ASK WOULD BE
UPDATED MORE FREQUENTLY. I DO REALIZE THAT ANY SYSTEM IS ONLY AS GOOD AS ITS PARTICIPANTS. I WOULD HOPE THAT MORE
FIRMS WOULD BECOME A PART OF THIS MARKET AND NOT CONTINUE
TO BE A PART OF THE CURRENT LIMITED SYSTEM. I BELIEVE THAT
WHEN THE PUBLIC BECOMES AWARE OF THE BENEFITS OF LISTING
THESE BONDS ON AN EXCHANGE TRADED SYSTEM AND IF THE REGULATORS SUCH AS THE SEC GET BEHIND THIS PROPOSAL THEN A MORE EFFICIENT AND EQUAL SYSTEM WILL EVOLVE. A MARKET SUCH
AS THIS WILL BE VISABLE ON QUOTE SYSTEMS SUCH AS REUTERS AND DOW JONES THUS ELIMINATING THE NEED FOR MUCH MORE COSTLY QUOTE SYSTMS THAT ARE NOT AVAILABLE TO SMALL FIRMS.I
AM STRONGLY BEHIND THE SWIFT ENACTMENT OF THIS PROPOSAL AND
HOPE THAT IT CAN BE EXPANDED TO INCLUDE ALL FORMS OF CORPORATE DEBT INCLUDING THE LISTED OF CONVERTIBLE AND ISSUES WHICH DO NOT HAVE UNDERLYING SECURITIES LISTED ON
THE EXCHANGE.