Institute Comments on Amendment to NASD Order Display Proposal

Washington, DC, December 7, 2000 - The Institute has filed a comment letter with the Securities and Exchange Commission on Amendment No. 8 to Nasdaq's SuperMontage proposal. The comment letter reiterates the Institute's support for the objectives of SuperMontage, in particular, increasing the transparency of limit orders in the Nasdaq market and the ability of those orders to interact with one another.

The letter also supports certain revisions that Nasdaq has proposed in Amendment No. 8. The letter states, however, that Amendment No. 8 introduces additional changes to SuperMontage that would significantly diminish the potential benefits of the proposed system including (1) the introduction of a new type of order, the "preferenced order," and (2) the introduction of a new execution algorithm for nondirected orders that would be based on price/size/time priority.