From: P. Ciemins [pciemins@hotmail.com]
Sent: Wednesday, October 24, 2001 1:20 PM
To: rule-comments@sec.gov
Subject: Re:Super SOES Reserve Size and Refresh Increment Changes



						95 Orient Way #1A
						Rutherford, NJ 07070

						October 15, 2001

Mr. Jonathan G. Katz, Secretary
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549-0609


Dear Secretary Katz:

I am writing to you to argue against the proposed rule changes for the Super 
SOES Reserve Size Display Requirement and the Refresh Increment Changes; 
both of these rule changes, if implemented, would adversely affect the small 
investor for three reasons.

First, by allowing market makers not to show their true size, the rule 
changes would greatly reduce the transparency of the market; this does not 
allow the small investor to get the best price on his or her investment.

The rule changes would also reduce the liquidity of the market; such is a 
contradiction of the original reasons behind the implementation of Super 
SOES.  The reduction of liquidity and transparency gives small investors 
less information about the market.  The only group of people to benefit from 
such a lack of information is the market makers.  By disguising the true 
size of orders, they would be able to play games with the market and 
essentially manipulate it.  Market makers would be able to limit the 
movement of stocks by only giving out 100 shares orders at a time instead of 
1,000 share orders; such would logically take ten times as long and 
therefore greatly slow down the price fluctuations of stocks.  The only 
group to benefit from such a slowing of price movements is the market makers 
because it would allow them more time to cover their positions being 
adversely affected by the price movement

Finally, Super SOES took approximately two years to implement, yet after 
only two months of it taking effect people want to change it.  If there are 
to be changes to Super SOES, it should be after everyone has had ample time 
to digest fully the original Super SOES rule and its implications.

The principal reasons why people around the world invest in the equities 
markets in the United States is that they are more liquid, transparent and 
fair than any other markets.  The proposed rule changes would only aid the 
market makers and would only defraud small investors.

As a Columbia College graduate with an MBA, I know that the Securities and 
Exchange Commission is greatly concerned with leveling the playing field for 
the small investor in the equities markets.  It is rather clear that the 
Super SOES Reserve Size Display Requirement and the Refresh Increment 
Changes would only benefit the market makers  at the expense of small time 
investors.

								Respectfully Submitted,



	Peter Ciemins


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