MEMORANDUM

TO: File No. S7-17-01
FROM: Patricia Albrecht
DATE: March 13, 2002
RE: February 27, 2002, March 5, 2002 conversations between Securities and Exhange Commission staff member and representative of Morgan Stanley Dean Witter

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CONTENTS OF CONVERSATIONS

Securities and Exhange Commission staff member Patricia Albrecht and Georgia Bullitt of Morgan Stanley Dean Witter discussed the futures industry practices of disclosing confirmations either on a round-turn or half-turn basis, depending on the customer's preference. They also discussed the futures industry practice of principal trading.

In addition, Ms. Albrecht and Ms. Bullit discussed the fact that the industry may need six months to a year to make changes to their systems to meet certain new confirmation requirements, and that while some changes would be costly, other changes would not require significant cost.