Subject: File No. S7-16-00, proposed Rule 11Ac1-5
Date:    09/13/2000 10:43 AM
     
     
US Securities and Exchange Commission 
Jonathan G. Katz, Secretary
450 Fifth St. NW
Washington, DC 20549-0609
     
     
     
Mr. Katz,
     
Jones & Associates, Inc. is registered broker-dealer and NASD member that 
trades large blocks of stock for institutions.  We would like to take the 
opportunity to opine on proposed Rule 11Ac1-5.
     
We feel that the term "market center" should be specific in excluding 
members, who are not market makers, specialists or ATSs, and execute or 
cross orders in the third market.  The cost of compliance with the rule 
would be unduly burdensome.  
     
Furthermore, because of the nature of institutional "third market" trading 
by non-market makers, the data would not provide meaningful information.  
     
Lastly, if the Commission were to exclude "market centers" with relatively 
few orders, the determination of "relatively few orders" should be set by 
number of executions and not volume.
     
Sincerely,
     
Steven A. Chmielewski,
General Counsel, Jones & Associates, In.