Friday, October 6, 2000
     
By E-mail to :rule-comments@sec.gov
     
Kimberly Van Maanen
University of Northern Colorado 
Greeley, Colorado
     
     
RE: File No. S7-16-00
     
Dear Mr. Katz:
     
I would like to take this opportunity to comment on the SEC proposed rule on 
Disclosure of Order Routing and Execution Practices.  After reading the 
Commissions Release on this matter I have come to an opinion that although 
the intentions of the Commission are sincere, it lacks elements of a possible 
great idea.   
     
If the Commission took a moment and thought long and hard about what would be 
best for the investor they should realize that a 56-page Release on the issue 
is not necessary, not to mention all the other wasted paper that the investor 
will receive in the future if Rule 11Ac1-5 where to be passed. It would not 
only be a waste of time and money, but also human capital.  Brokers would have 
to spend countless hours attempting to explain to their clients the reasoning 
and logic behind such a report each month.  Time in which a broker could or 
should be spending on getting their client the best price for their 
investment. 
Wouldn't it make more sense for the Commission to try to eliminate the 
possibility of market fragmentation, rather than add to it?  You state in the 
release that, "â?|there is no requirement that orders be routed to the market 
center that is displaying the best prices, even if that price represents a 
customer limit order."  There is no requirement because the Commission is so 
busy adding to the market fragmentation with silly rules and proposals that 
it is impossible for brokers to know where the best price is.  It is also 
stated that, " â?|approximately 85% of the executed market orders in NASDAQ 
securities are routed to market centers when they are not quoting at the best 
price."  This is an appalling statistic. I pose this one question to you: 
"How is it possible for a broker to find the 'best execution' for their 
customer if it is almost impossible for them to know exactly where the best 
execution price is being offered?"  
My answer is this; Why not integrate all the markets into one single national 
market?  Then there would not be as much or if any, market orders that do not 
receive the best execution price.  The investor would know automatically that 
she/he got the best price possible.  The investor would also not have to sit 
through hours of explanation from their broker that would be required if rule 
11Ac1-5 were to pass.
Then market centers could compete on servicing their clients, rather than 
competing on quality of execution.  Markets centers and brokerage firms would 
not have to compete on quality of execution because the best execution price 
would be in one place, rather than four different places at four different 
prices.  Brokers could compete on quality customer service.   
     
In conclusion, rule 11Ac1-5 is a silly idea.  The investor does not need 
their broker to send them 56-page progress reports on execution of their 
orders; we have the SEC to do that.  What we do need is a little more 
cohesion in the market centers themselves, that way investors know they are 
getting the best price before they put in their orders.  
     
Thank you for your time, 
     
     
Kimberly Van Maanen