March 25, 1998
Jonathan G. Katz, Secretary
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549
Re: SR-NASD-98-21
Dear Mr. Katz:
North American Institutional Brokers welcomes the opportunity to express our view in support of NASDAQs recommendation to expand the pilot program allowing market makers to quote their actual size whether order driven or proprietary interest.
The effect of the SECs Order Handling Rules has removed the motive for establishing and mandating minimum quote sizes enabling customers to have their orders reflected in the quote. In addition these minimum sizes have no longer substance, since the rule provides for improved price discovery for all investors.
As a regional market making firm, doing business with and for institutional and other professional customers, we believe that the removal of artificial size requirements will benefit the market. By allowing true supply and demand forces together with true competition among market makers and removing artificial volatility will warrant more capital commitment and thus become more favorable to investors.
We emphatically urge the Commission to increase the pilot program regarding actual size to 150 stocks and eventually to all NASDAQ securities.
Sincerely yours
Marcos Konig
President and CEO