From: Mike Ianni 
Sent: Thursday, November 07, 2002 6:05 PM
To: rule-comments@sec.gov
Subject: SR-NYSE-2002-19 and SR-CBOE-2002-03


 
I think this is a very good proposal.  A portfolio-based margin system 
is the way to go.  Customers should no longer have come up with Margin 
Requirements as set forth in Regulation T if there are appropriate 
offsets in his accounts.
 
The only question I have is the minimum equity requirement of $5 Million.  
In a similar proposal, SR-CBOE-2002-03, the CBOE stated that they would 
consider lowering the minimum equity required:
 
"Whether the account equity requirement should be lowered to allow 
participation of more customers will be assessed at the end of the 
pilot program period"
 
 
I don't think it is right that customers, who are well capitalised (but 
who have less than $5 million in equity) should have to put equivalent 
margin, on positions that have equal offsets, to those positions that 
are truly speculative.  After all, margin is suppose to reflect the 
amount of risk a particular position has.  
 
Please consider lowering this minimum equity requirement for portfolio-
based margin systems.
 
 
thank you,
 
 
Mike Ianni
Private Investor