Date: 7/6/99 3:00 PM

Mr. Jonathan G. Katz


Securities and Exchange Commission

450 Fifth Street, N.W.

Washington, DC 20549

Dear Mr. Katz:

I'm Bernie Schaeffer, Chairman of Schaeffer's Investment Research, Inc. ("SIR"), a provider of equity option research and trading recommendations that are distributed on an impersonal basis to subscribers to our various newsletter-based services. I am also a financial journalist through the vehicle of my monthly column in Bloomberg Personal Finance magazine.

I appreciate the opportunity to comment on the application of the International Securities Exchange ("ISE") to register as a national securities exchange under the Securities Exchange Act of 1934. As Chairman of SIR I support the ISE's application and urge the commission to approve it.

As a provider of option trading recommendations to investors I naturally support developments in the industry that will serve to lower their transaction costs, decrease their slippage and increase order transparency and market liquidity. I believe that the introduction of the ISE into the options marketplace will help further each of these objectives by increasing the pool of market makers for a large number of option classes, introducing additional competition so as to reduce bid/asked spreads on many series and providing quotations in size to provide customers with greater certainty and liquidity.

I urge the Commission to approve the ISE's application for registration as a national securities exchange. If you have any questions on my comments, please do not hesitate to contact me.


Bernie Schaeffer