From: Janjigian, Vahan [VJanjigian@forbes.com]
Sent: Thursday, February 27, 2003 2:57 PM
To: rule-comments@sec.gov
Subject: File Nos. SR-NASD-2002-154 and SR-NYSE-2002-49

I would like to comment on the section titled, “Restrictions on Compensation 
to Associated Persons.”  First of all, since buy-side analysts work for firms 
that are not involved with investment banking activities, this rule really 
applies only to the sell side. In general, the provisions seem reasonable and 
make sense.  And I certainly agree that it would be unwise to compensate 
analysts for investment banking activities. 

Yet I strongly believe the compensation decision should be left to the employer.  
Regulators should not dictate how businesses must compensate employees.  Instead, 
they should call for full disclosure.  As an investor, I don’t care if the analyst 
is compensated for bringing in investment banking business, as long as this is 
fully disclosed and I am aware of it. Of course, in such cases, I would probably 
choose to discount the analyst’s opinions. 

While these provisions are excellent recommendations, making them requirements is 
going much too far. 

Vahan Janjigian, Ph.D., CFA
Forbes, Inc.
60 Fifth Avenue
New York, NY  10011
212-620-2214