Date:    04/01/2000 2:50 PM
     
     
Dear Sir or Madam:   I am a client of Interactive Brokers LLC engaged in 
trading options listed by the four options exchanges. Although I have 
missed the official comment period on the proposed exchange linkage, I 
do have some comments to submit at this time.  Further, I am very 
distressed at the new rules implemented by the CBOE with respect to the 
handling of customer orders.
     
              Regarding the proposed linkage, I make the following
points:
     
                     1. All quotes displayed by each exchange must be
electronically tradable for guaranteed sizes  --providing automatic 
fills. Orders must not be held up and quoted prices must be actually 
tradable prices (this is currently not the case). Attempts to ensure 
best price execution can only succeed if quoted prices are tradable.
     
                    2.  National quotation systems must be
state-of-the-art and provide real-time data to all market participants. 
Recent attempts to update such a system have resulted in quotes being 
delayed for up to 5 minutes for periods of 1 hour!  This is unfair and 
unacceptable to outside participants.
     
                  3.  No time must be given for various exchanges to
consider whether to fill an order or not and if not send it to another 
exchange with the NBBO.   In today's fast moving dynamic market, any 
delay even 15 to 30 seconds is unworkable in an attempt to somehow 
provide a better fill.  Fills must be immediate!
     
             4.. Any exchange linkage plan must consider  the
implementation of uniform trading rules for all options orders. Current 
rules differ from exchange to exchange; from stock to stock; and from 
time to time within each stock!
     
     New rules introduced by the CBOE now make it increasingly difficult
to have access to resting customer orders in the limit order book. In my 
recent trading of QCOM at the CBOE, I have experienced on numerous 
occasions instances where my order entered to hit the prevailing bid or 
offer (a customer order) has encountered removal of the automatic RAES 
execution; handling of my order manually with serious delays and loss of 
the ability to modify or easily cancel such an order; front running of 
such orders by the market makers who will execute against the resting 
order for their own benefit.  Such rules can be arbitrarily implemented 
with no notice to outside customers.  This is a throw back to the "old" 
days of option trading contrary to the SEC intentions to establish freely 
competitive efficient option markets.
     
        Dealing through Interactive Brokers has given me direct access
to electronic matching engines of the exchanges and the ability to 
employ strategies that depend on instantaneous order execution.  Such 
arrangements serve to enhance the development of freely competitive 
option markets that put outside customers on a level playing field with 
exchange market makers.  Recent rule changes and proposals by the option 
exchanges seem intent on denying such access and free competition. The 
SEC must take seriously these developments and investigate the 
deterioration of trading conditions for all but a few privileged market 
participants.
     
     
Thank you for you attention to this matter.
     
     
Yours truly,
     
     
P. Robert Fenwick