Wednesday, September 20, 2000 Mr. Jonathan G. Katz, Secretary Securities and Exchange Commission 450 Fifth Street, NW Washington, D.C. 20549-0609 Subject: File No. S7-16-2000 Dear Mr. Katz: It is our pleasure and a privilege to be given the opportunity to comment on proposed rule 11Ac1-6. We are a group of students from Florida International University. Our names are Ruben Bermudez, Gayle Mendez, Angee Eysallenne, Theresa Bryant and Alfonso Suarez. We decided to provide our comments in order to fulfill our scholastic obligations. However, in the process, we have developed a deep concern for the issue at hand and have also been educated in the related matters. We believe that our input can make an impact on the adoption or rejection of this rule. Making a decision on what subject matter we were going to contribute our time and effort on for the semester was a very difficult task. We unanimously agreed upon proposed rule 11Ac1-6. It is sure that upon the onset of the project we all had different expectations as to what we would learn from our research but at this point we feel confident about the consequences of the adoption or rejection of the proposed rule 11Ac1-6. We believe a rule of this sort should be put in place. The securities industry is a very complex one, where most of the time the individual investor is not aware of the manner in which operations occur. Although most trades are performed at the touch of a key, internally and operationally there are many other steps that occur in a matter of seconds. The proposed rule gave us the opportunity to become very well informed and even consider becoming future market participants. All transactions that are the result of broker-dealer and investor relationships should be inclusive of the rule. The reason being is for one it provides consistency and comparability for investors and other interested parties. Excluding any financial instruments from the scope of the rule would provide room for the same deficiencies the proposed rule is attempting to correct. Allowing small cap equities that have the ultimate goal of growth to be excluded is disadvantageous not only to investors but it is also disadvantageous to the firms providing those equities. Speculatively, broker dealers would give more attention to those order execution types that are non-regulated in comparison to those that fall under the effect of the regulation being discussed. This in turn could result in a less competitive and more confusing market environment. If this rule encompasses all financial instruments, in addition to providing a solid foundation for the market would also better educate its participants. This is a positive externality. The institution of markets will eventually become more accessible, understandable and transparent thus facilitating participation by those who currently do not partake of the wealth connected to the interest paid on capital. After receiving the comments from friends in the brokerage business, we have also seen that a significant percentage of them have strong positive opinions when it comes to new federal regulations that will make the business more transparent and improve the investors' perception. The rule will definitely favor those brokers that are doing business in the most efficient way because their cost efficiency, quality, and audacity to conduct business will be known to the public via mandatory reports and this will greatly improve their image before the investor community. On the other hand the rule will pose a threat to those broker dealer firms and venues that are not performing to the standards required due to the exposure of their practices. This will force them to improve their systems and quality or go out of business. We believe the rule is a great tool to continue refining the investment's market, promoting competition and providing better service to the customer. We are also aware that there are rules that presently require brokerage houses to disclose fees involved in the acquisition or sale of a financial instrument. But in the other hand, investors are not informed of other internal costs associated with the execution of that trade. In the past, some investors had the wrong perception of the industry where a "broker" was perceived as a "salesman," incorrectly assuming that costs were hidden and prices manipulated. In recent years this perception has been changed as the industry regulations became stronger, new rules and regulations were put in place in order to protect the individual investor as well as the brokerage houses. A rule of this sort will clear even more the image of brokers, providing the individual investor with a transparent transaction where all costs to acquire or sell a financial instrument are disclosed. Best Regards, Ruben Bermudez, Gayle Mendez, Angee Eysallenne, Theresa Bryant, Alfonso Suarez.