From: jeremy zucker [jbzucker@yahoo.com]
Sent: Friday, October 19, 2001 1:18 PM
To: rule-comments@sec.gov
Subject: RE: Alert#2001-157, 158

304 W. 92nd Street #5B
New York, NY 10025
19 October 2001

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

Dear Mr. Katz,

I am writing to express concern with Alert #2001-157
and 158 regarding SuperSoes reserve size display
requirement and refresh increment change. The
SuperSoes system has been in place for a very short
time during which the markets were trading
historically low volume. I believe that any changes to
the marketplace would be better implemented when
market participants have had more time adjust to the
new market framework. Also, regulators would have a
better idea of how changes would affect trading when
the market is more active.

The proposed changes to the system could, I believe,
serve to widen spreads. Under the current system, a
market maker showing reserve size can post a quote on
the Nasdaq screen and execute an order for the full
amount or in several executions. The proposed changes
would encourage market makers to show 100 shares, see
how quickly the order was executed, then move their
quote higher to assure them of the best possible
price. In this way, a market participant is encouraged
to provide the least amount of liquidity until they
find the highest price. This is a good system if you
are a market maker because you’ll always be trying to
sell at the highest price. For the individual investor
this will hurt executions since there will be a lot
less stock available at each price. Spreads will
widen, as will volatility. 

If the proposed rules go into effect, market makers
will be able to execute their orders at the highest
prices, maximizing their profits, and be paid to do
this. Individual investors will be getting the worst
executions and paying higher prices for it!

Thank you for your attention in this matter.

Sincerely,


Jeremy Zucker
Series 7, 63, 55, 24



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