to sell com- mercial paper with financial information vendors such as Bloomberg, Reuters, and Telerate. Although commercial paper is a short-term security, it is issued within a longer term program, usually for three to five years for Euro- pean firms: U.S. commercial paper programs are often open-ended. For example, a company might establish a 5-year commercial paper pro- gram with a limit of $100 million. Once the program is established the company can issue commercial paper up to this amount. The program is continuous and new paper can be issued at any time, daily if required.   EXHIBIT 5.1 Commercial Paper Outstanding       Source: Federal Reserve     In the case of dealer placed commercial paper, the issuer uses the ser- vices of a securities firm to sell its paper. Commercial paper sold in this manner is referred to as dealer paper. Competitive pressures have forced dramatic reductions in the underwriting fees charged by dealer firms. Historically, the dealer market has been dominated by large invest- ment banking firms because the Glass-Steagall Act prohibited commercial banks from underwriting commercial paper. In June 1987, however, the Federal Reserve granted subsidiaries of bank holding companies the power to underwrite commercial paper. Commercial banks began imme- diately making inroads into the dealer market that was once the exclusive province of investment banking firms. This process was further acceler- ated when the Gramm-Leach-Bliley Act was signed into law in November 1999. The reforms enacted in the Gramm-Leach-Bliley Act repealed the Glass-Steagall Act that mandated artificial barriers between commercial banks, investment banks, and insurance companies. Now each is free to expand into the others businesses.   The Secondary Market Although commercial paper, as noted, is the largest sector of the money market, there is relatively little trading in the secondary market. The rea- son being is that most investors in commercial paper follow a "buy and hold" strategy. This is to be expected because investors purchase com- mercial paper that matches their specific maturity requirements. Any sec- ondary market trading is usually concentrated among institutional investors in a few large, highly rated issues. If investors wish to sell their commercial paper, they can usually sell it back to the original seller either dealer or issuer.