From: Phllykng35@aol.com
Sent: Thursday, January 23, 2003 5:10 PM
To: rule-comments@sec.gov
Subject: re:33-8150
Mr. Jonathan G. Katz
Secretary
Securities and Exchange Commission
450 Fifth Street, N.W. Mailstop 6-9
Washington, DC 20549

Re:     Implementation of Standards of Professional Conduct for Attorneys, 
Release Nos. 33-8150, 34-46868; File No. S7-45-02 

Dear Mr. Katz,

I am a former employee of the Philadelphia Stock Exchange, I resigned my 
position in september due to illness in the family. I must tell you that 
this proposal cannot be affective when a chairman of a company runs a 
company unchallenged and when a board of directors, hand picked by the 
chairman and his close allies on the board rubber stamps all of his decisions. 

Under what situation would you expect any one employed or paid by a company 
challenge or expose any wrongdoing in a company when they are being paid to 
look for loopholes in the law to allow these shenanigans to go on.  

At the PHLX , the lawyers know that certain issues violate the rules yet 
look for loopholes to explore to continue to violate them and when the 
members start asking questions, they are hit with more fees or put off 
indefinately. I know there are two investigations that are 2 years old that 
involve customers getting crossed at worse prices with the floor brokers 
shutting out the market makers using interpretations of the crossing rule 
which loose at best. The market makers that complained of these violations 
were Wolverine and Market Street securites and they have been put off ever 
since. The Chairman is fully aware and has directed that these instances 
not be policed. 

The PHLX regulators, whenever the SEC comes in, stonewalls the investigators 
and  spends the  months before the SEC comes in for their audits reviewing 
and doctoring thier casetrack in order to clean any information that may raise 
eyebrows among the investigators, this is done with the oversight of the lawyers. 

I ask again how are you going to get the lawyers to "rat out" the people who 
are paying thier checks, You would have to provide a channel that will listen 
at the SEC and provide sort of like a whistleblower status for the employee 
that talks.

If you have any questions e-mail me back, 

Richard Mariani