To: LTK007 who wrote (320 ) 4/25/1999 8:18:00 PM From: EyeDrMike Respond to of 4443
Insitutional "thoughts" on anonymous alternate trading systems. Here a few excerpts from letters written in support of anonymous alternative trading systems by the Institutions themselves, when the SEC was considering full disclosure: Nov, 27 1988 OHIO VALLEY MANAGEMENT J. Eric Vaughan President "As an institutional money manager, we depend on quick and anonymous trading systems to execute many of our orders. The past changes from the SEC regarding public display of orders has been horrendous for institutions and principle market markers alike, and has rendered the ability to seamlessly trade blocks of stock difficult if not impossible on small, less liquid names. " Nov 25, 1998 Longview Capital Management John D. Robinson Head Trader"Longwood Asset Management is a registered investment advisor which manages about $130 million in retirement and hedge-fund accounts. There are situations when it is in the best interest of both our customers and the market in general that we elect not to disclose large orders in the public quote. Not only would disclosure prevent us from obtaining the best possible execution for our accounts, but it would also unnecessarily add volatility to the market, increase spreads and give a false impression of increased liquidity in the market. Upstairs trading provides an effective means for us to execute large orders while causing little disruption in the market. " Nov 1998 Caldwell and Orkin Russell Rhoads Michael B. Orkin Director of Equity Trading Chairman and CEO "As professional money managers become responsible for managing larger amounts of the investing public's money, it is glaringly evident that we need flexibility in executing certain trading strategies. This involves having access to systems which allow us to move larger quantities of stock in an anonymous fashion without drastically influencing the price of those securities. " Nov 24, 1998 Bowman Capital Management William J. Haggerty Managing Director of Operations "To avoid impacting the market for a security, money managers need to maintain anonymity and control over their orders. Once an institution's interest or the size of its interest in a particular security becomes known, the price immediately becomes prone to manipulation. " Nov 23, 1998 Wellington Management Company Patrick J. McCloskey Senior Vice President"Wellington Management Company, LLP is one of the largest institutional investors in the U.S. Our clients include a significant number of 401(k) and state retirement plans. Although we are a major player in the NASDAQ market, our constituents are primarily individual investors who rely on our expertise to meet many of their investment needs. Forcing display of our order size will ultimately result in poor executions to the detriment of our clients. It is a simple fact of supply and demand that displaying large institutional orders to the market invites price dislocation when there is no contra side interest. Without the benefit of established mechanisms to protect the size of our orders, such as those provided by electronic brokers, we are faced with the undesirable alternative of exposure to the street, losing our anonymity. Moreover, I believe that the impact of recent SEC rules on market-maker spreads has resulted in the high volatility of the markets that we are seeing these days. Adding a display requirement for institutional orders will not benefit the execution of our clients business. I therefore recommend that the SEC not adopt any mandatory display rule." Nov 18, 1998 Westchester Capital Management, Inc. Roy Behren"Having access to multiple sources of liquidity without having to reveal our ultimate intent to the entire market increases our funds' performance and ultimately our investors' bottom lines. To avoid the market impact that a fully transparent quote would have on our orders, we may have to take trades to less transparent dealers or compromise executions by breaking up orders into smaller pieces. Whatever we are ultimately forced to do, our clients will suffer in the form of increased execution costs."