Rho Trading Securities, LLC
440 S. LaSalle Street, Suite 620
Chicago, IL 60605-1028
(312) 362-4990
(312) 362-4941 fax

September 11, 2003

Jonathan G. Katz, Secretary
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549-0609

Reference: SR-BSE-2002-15

Dear Jonathan:

I am writing in support of the Boston Options Exchange's (BOX) most recent filing with the SEC and urge the regulators to approve the BOX proposal and amendments currently under consideration.

Among the benefits that we see are:

  • Increasing the competitive dynamic that fuels our financial markets and our basic national capitalistic philosophy

    1. A competitor market to the BOX, the International Stock Exchange (ISE), has made one or more significant changes to their rules and practices in response to the possible entry of the BOX into the electronic options community. These changes were unlikely to have been made without the increased competition suggested by the BOX application being held at the SEC. These changes (e.g. market makers required to honor their posted markets) have only served to tighten markets and increase trading opportunities for retail and professional traders.

    2. Pursuing novel methods of achieving tighter markets benefiting customers (i.e. The price improvement mechanism.). The effect of the price improvement policy is tighter markets (trading in pennies), increased volume (crosses) and eliminating arcane workaround kludges to effect pricing objectives (splits).

    3. Opening up to the public the opportunity to participate in trades that they were unable to participate in previously through the increased volume and increased opportunity.

  • Fueling the investment in electronic markets and increasing domestic momentum toward developing electronic trading platforms and refining existing electronic marketplaces. This investment in improved systems will be increasingly important for the United States in terms of maintaining control over exchanges listing domestic products.

I believe that the model proposed by the BOX and currently under consideration by the SEC is one that, if approved, will benefit the industry through:

  • Increased competition

  • Increased volume

  • Tighter markets

And will benefit both the professional and retail market participant through:

  • Increased opportunity

  • Increased transparency

  • Increased granularity of pricing

Therefore I once again urge the commission to promptly act on the BOX proposal and to approve it without hesitation or question as to its anticipated positive impact on markets benefiting all categories of market participants.

Very truly,

Rho Trading Securities, LLC

By: John Keazirian
Its: Executive Vice President