Subject: File name: 34-42755

Date:    06/07/2000 9:11 PM
         
Hi,
First off I think it's crazy to have 4 Exchanges trade the same things. 
Only a government would propose something as stupid as this.
     
The SEC has has forced the Options Exchanges into a situation that has 
made the markets "unfair & disorderly", rather then the way they were 
prior to Multiple Listings, which was "fair & orderly."
     
As a result of government interference, the PSX and PHLX have now paid 
extortion money to the Justice Dept. in the form of fines.  In the mean 
time, the Options Markets are worst off now then before.
     
Before..  You claimed "monopoly" and a "gentlemen's agreement" existed 
prior to Multiple Listing.  In the mean time, the highest bid and the 
lowest offer were always at the same market place (what else could 
someone want).  This also insures maximum liquidity and maximum depth of 
markets.
     
Now.. because there are 4 places that trade the same thing, Payment for 
Order Flow has come to the Options Markets.  There are trade thoughts 
constantly because no one knows where to send the order.  They now send 
it to the highest bidder FOR THE FLOW (highest payer for the order that 
is).
     
There are about 5-6 things wrong with Multiple Listing:
     
1.  All the Brokerage Firms must have a presence on all 4 Floors.
     
2.  The amount of quotes sent through the system are 4x to many then 
necessary.
     
3.  Spreads are coming into line anyway.
     
4.  Payment for Order Flow.
     
5.  Specialists on the Primary Options Exchanges, try to hit bids or 
take offers (on the same option) on the other exchanges and the other 
exchanges never honor their markets.
     
6.  When spreads are executed, if it's a 4 sided spread, how can you 
expect each side to be done at a different Exchange?  What if there is a 
problem?  Are the 4 corners of the country to be involved.
     
Chris Delzio
8 Oak Street
Harrison, NY  10528