From: Robert Gaida [rgaida@msn.com]
Sent: Tuesday, October 30, 2001 8:51 AM
To: rule-comments@sec.gov
Subject: rule change

October 16, 2001

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

Re: SuperSoes Reserve Size Display Requirement and Refresh Increment Rule 
Changes (SR-NASD-2001-66)

I am writing to express my concern regarding the "SuperSoes Reserve Size 
Display Requirement and Refresh Increment" changes proposed by NASD take 
effect on November 1, 2001. The changes proposed to the SuperSoes system 
will defeat many of the positive steps taken by the SEC to ensure a fair and 
equitable marketplace.

One purpose of SuperSoes is to ensure liquidity on the inside market. If 
enacted, the new changes would effectively reduce liquidity. With a refresh 
size of one hundred shares it would take up to ten times longer to acquire a 
one thousand share positions in any given stock. This would clearly work to 
the benefit of the Market Maker in any given stock and hinder the small 
investor.

The new changes also provide for a less transparent trading forum. Lack of 
transparency in the marketplace will ultimately permit a dishonest 
marketplace to exist. The less transparent the markets, the more prevalent 
the existence of dishonest trading practices. Transparency is also important 
for investors to make informed decisions.  The less transparent the market 
place, the less efficient it becomes.

Market Makers have a responsibility to provide liquidity to the inside 
market and ultimately receive benefits to make a market in a particular 
stock, such as shorting stock on a downtick and receiving monetary 
compensation for this responsibility. Enacting this rule will permit a 
Market Maker to stay on the inside market without providing liquidity to 
that market, in essence negating any Market Maker responsibilities while 
still taking advantage of the benefits of Market Maker status.

Finally, this change would be a violation of Section 15A(b)(6) of the 1934 
Exchange Act, because it would create a pricing structure that is 
discriminatory to NASD members who do not make markets.  These members would 
not be able to participate in the revenue stream created by the payment for 
liquidity.

The investment community has not even had enough time to evaluate the 
functions and benefits of SuperSoes. Investors need more time to become 
familiar with the present trading environment before any further 
modifications can be fairly made.

Sincerely,
Registered Representative
Robert A. Gaida Jr.


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