[16594]
October 1, 2003
TO: EQUITY MARKETS ADVISORY COMMITTEE No. 22-03
SEC RULES MEMBERS No. 127-03
RE: INSTITUTE COMMENT LETTER ON NYSE PROPOSED RULE CHANGE REPEALING
RULE 500
The Institute has filed a comment letter with the Securities and Exchange Commission
on the NYSE’s proposed rule change repealing NYSE Rule 500 relating to the delisting of a
security by an issuer. The most significant aspects of the comment letter are summarized
below.
The comment letter supports the proposed rule change. In particular, the letter states
that easing the NYSE’s delisting requirements should: create a more level playing field for
markets trading securities currently listed on the Exchange; bring the NYSE’s requirements in
line with the requirements of other exchanges; and continue to provide adequate investor
protection if an issuer chooses to delist its shares from the Exchange. The comment letter states,
however, that while the Institute supports the easing of the delisting requirements, we hope
that the NYSE and other exchanges will, at the same time, maintain strong listing standards and
not engage in a “race to the bottom” in an attempt to maintain and/or increase listings on their
respective markets.
Ari Burstein
Associate Counsel
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Attachment (in .pdf format)