Comments also submitted via HTML attached file.

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

Re: NASD and NYSE Rule Proposals Regarding Research Analyst Conflicts of Interest (File Nos. SR-NASD-2002-21; SR-NYSE-2002-09)

Dear Mr. Katz:

I am submitting this letter in response to the request of the Securities and Exchange Commission for comments regarding rule proposals submitted by the NASD and the NYSE relating to research analyst conflicts of interest.

Jovus, Inc., located at 14 Wall Street in New York City is a software development firm that specializes in Sell-Side Equity Research Software and Systems. As consultants and software developers, Jovus is not directly involved in the regulatory issues that surround the production and distribution of research material. However, Jovus does work closely with many bulge bracket, large, medium and small companies who depend on us to automate the processes involved in authoring, compliance, editing, publishing and distribution of research. We therefore have a vested interest in the inclusion of rules that are clear, concise and logical.

Although the rules set forth appear to thoroughly address conflict issues before they arise, they do little to incorporate simple reporting standards that could dramatically improve the readability of reports, as well as the level of automation used to create them. Improved standardization in nomenclature, formatting and data inclusion/position within a document would enable users of research to quickly compare reports from the same or different companies, locate desired information faster and assess what they read with a greater confidence from knowing that when two analysts say the same thing, they mean the same thing. An additional benefit would be the reduced costs incurred by firms (due to improved automation) to produce their research.

It is clear that the industry supports standardization, as is evidenced by initiatives such as, the consortium of buy and sell side firms. Companies that incorporate well-defined, enterprise-wide standards in research content and formatting offer their buy-side clients and the general public greater objectivity, by design. More formal, required, industry standards would further improve the state of analysis and reporting.

I appreciate the opportunity to submit this comment letter. Should you wish to discuss this matter further, please feel free to contact me.


Alex Massimi
Senior VP for Business Development
Sell-Side Equity Research
Jovus, Inc.
14 Wall Street, 20th Floor
New York, NY 10005
(212) 618-1453 office
(212) 618-1450 fax
(914) 469-0497 cellular