Mr. Jonathan G. Katz

Securities and Exchange Commission

450 Fifth Street, NW

Washington, DC 20549

RE: File No. S7-12-98

Dear Mr. Katz,

We are submitting this comment letter on proposed Regulation ATS to express our concern regarding this new proposal. 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.

This new proposal ,we believe, will make the ability to trade even more difficult. The volatility of individual stocks will increase, and the only individuals who would benefit from this and prior public display regulation changes are the electronic day traders.

I would urge careful thought as to the consequences of this implementation.

Thank you for your consideration.

Sincerely,

J. Eric Vaughan

President

cc:

The Honorable Arthur Levitt, Chairman

The Honorable Norman S. Johnson, Commissioner

The Honorable Isaac C. Hunt, Jr., Commissioner

The Honorable Laura S. Unger, Commissioner

The Honorable Paul R. Carey, Commissioner

Richard R. Lindsay, Director, Division of Market Regulation

Erik R. Sirri, Chief Economist

Annette Nazareth, Acting Director, Division of Investment Management