{sent via email, original to follow}

December 24, 2003

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

Re: Response to SR-NSCC-2003-21

Dear Sir:

Placemark Investments, Inc. participates in the separately managed account industry. We respectfully submit this letter in response to the request for comments to Release No. 34-48846: "Notice of Proposed Rule Change Relating to the Separately Managed Accounts Service, SR-NSCC-2003-21."

We question the need for a central clearing authority in this industry and therefore oppose the request. In our opinion, it may be redundant in an industry well served by the private sector, it may be an inappropriate role for an SRO, and it may add unnecessary cost into the business, thus increasing the price investors must pay. Further, we respectfully oppose this filing due to unresolved questions about the cost and pricing of such a service.


Lee Chertavian
Chairman & CEO