Beverly Gordon - Page 7

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               On December 31, 1985, Mr. Gordon purchased a seat on and               
          became a member of the AMEX by purchasing an option-trading                 
          permit from Moore.  Thereafter, during 1986 Mr. Gordon, who was             
          registered with the SEC as a broker/dealer, registered with and             
          operated on the AMEX as a market maker in stock options (i.e.,              
          options in which the underlying interest is stock) and index                
          options (i.e., options in which the underlying interest is an               
          index that is the measure of the value of a group of stocks or              
          other securities).6  All of those options were listed and traded            
          on the AMEX and subject to the respective rules and regulations             
          of that exchange and the SEC.                                               
               As an options market maker, during 1986 Mr. Gordon (1) was             
          obligated to comply with the respective rules and regulations               
          prescribed by the SEC and the AMEX, (2) was required to provide             
          liquidity for customer orders to be filled on the AMEX, (3) was             
          obligated to create a market in options by offering simulta-                
          neously to buy and sell options at a particular price for certain           
          stock, and (4) was required to make bids and offers in all option           
          classes consistent with a fair and orderly market.  As an options           


          6  In the "Stipulation of Facts as to Ronald Gordon", Mr. Gordon            
          and respondent interchangeably referred to Mr. Gordon's activi-             
          ties during 1986 on the AMEX as a market maker in stock options             
          and index options for his own account as his activities as (1) a            
          "market maker", (2) an "option market maker", (3) "a dealer in              
          equity options", and (4) a "listed equity options market maker".            
          We shall refer to Mr. Gordon's activities during 1986 on the AMEX           
          as a market maker in stock options and index options for his own            
          account as his activities as an options market maker.                       




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