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To: Darren who wrote (781)	6/8/1998 9:04:00 PM
From: steve goldman	Respond to of 3216

Roughly speaking, I believe the NASD is actually a bit tougher on traders about SOES. I dont recall codes or case law offhand, but the NASDAQ distributes a monthly/quarterly newsletter that discusses issues with NASD regulation. Several times I have seen the discussion about SOES traders, quantity of trades, violative...I havent seen or need to see if in over 6 months or so, i think the last time we had a discussion about SOES tregulations, etc. , on the Trading Desk . I'll look through the fliers tommorrow and see if I can find something. I think it came more from case law, fines levied to firms and investors for doing X number of trades in the same stock, same day. " Not if it's your own money and not unless you are using SOES to "accumulate a position." , my point exactly is that I think caselaw goes beyond your statement. remember we're talking soes, not isld, ecns, snet, routing to third market makers, etc. pure soes. I'll see if i can find it tommorrow or i'll call the nasd. -Steve@yamner.com