August 8, 2000
     
SECURITIES AND EXCHANGE COMMISSION
     
Re:Decimalization
    http://www.sec.gov/rules/othern/decimalp.htm
     
Sir:
     
I am concerned that little attention is being addressed to the possibility that 
a 1 cent MPV for equities may lead to multiple trade tickets and therefore 
higher commissions for many investors and traders. I have asked Ameritrade for 
their commission policy if an execution were to get split at 15.12, 15.11 and 
15.10 on one limit order at 15.12, and, after more than 24 hours, there has been
no response. I've encouraged Nightly Business Report to do a story, and there, 
too, have gotten no response.
     
Has the SEC considered this likelihood? 
     
I think we need a consensus about fairness for investors, and to me, 
possibilities include (a) to average the tickets and charge one commission, by 
the formula agreed upon by that customer and that firm (or the "standard" rates 
then in effect), or (b) to charge no more than the commission that would have 
been charged had all shares traded at the highest of the various prices. The 
multiple transactions probability could easily lead to double or triple 
commission for the many transactions now occurring online at fixed transaction 
prices (under 3,000 shares or so at some brokers). Institutions and others 
paying negotiated rates of cents per share may not be affected.
     
Because the SEC fee of 1/30,000 of sales proceeds is rounded up, the SEC may 
want to consider giving direction to a standard policy or treatment, so we don't
have a rounding windfall for the SEC that was not intended.
     
I'd be happy to spend more time on this, and give a more detailed analysis and 
recommendations.
     
Thank you.
     
Sincerely,
     
Bernard E Klein
SONAR RADIO CORPORATION
3000 Stirling Road
Hollywood, FL  33021-2099