1 See Memorandum to Equity Markets Advisory Committee No. 14-00 and SEC Rules Committee No. 36-00, dated March 9,
2000.
[11776]
April 4, 2000
TO: EQUITY MARKETS ADVISORY COMMITTEE No. 22-00
SEC RULES COMMITTEE No. 53-00
RE: INSTITUTE COMMENT LETTER ON OPTIONS MARKETS LINKAGES
______________________________________________________________________________
The Institute has filed a comment letter (attached) with the Securities and Exchange
Commission supporting the proposed plans filed by the options exchanges to create and operate an
inter-market options linkage.1
The comment letter states that the Institute believes that inter-market linkages are essential to
the effective functioning of the options markets, as they are in the equity markets, and that the
establishment of inter-market linkages will further the goals of the Exchange Act. In addition, the
comment letter states that inter-market linkages would benefit investors by helping to assure that an
order gets the best price at the point of sale, even if the market where a broker routes an order may no
longer be offering the best price by the time the order arrives. Inter-market linkages therefore assist
brokers in fulfilling their responsibility to provide best execution for customer orders. Finally, the letter
states that the Institute will examine in greater detail in its comment letter on the SEC’s market
fragmentation concept release whether linkages should require routing of orders based on price/time
priority and who should have access to linkages.
Ari Burstein
Assistant Counsel
Attachment