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* Shares fall more than 12 percent in early trading

* Nasdaq says it will change IPO procedure

* “Priced for perfection” at $38 – analyst

By Chuck Mikolajczak and John McCrank

May 21 (Reuters) – Facebook stock sank on Monday in

the first day of trading without the full support of the

company’s underwriters, leaving some investors down nearly 25

percent from where they were Friday afternoon.

Facebook’s debut was beset by problems, so much so that

Nasdaq said on Monday it was changing its IPO procedures. That

may comfort companies considering a listing but does little for

Facebook, whose lead underwriter Morgan Stanley had to

step in and defend the $38 offering price on the open market.

Without that same level of defense, its shares fell $4.64 to

$33.67 in the first minutes of trading. That represented a

decline of more than 12 percent from Friday’s close and about

24.4 percent from the intra-day high of $45 a share.

Volume was again massive with more than 52 million shares

trading hands in 15 minutes. Nearly 581 million shares were

traded on Friday in the five or so hours that the stock was

open.

As the stock fell, there was a long list of questions —

ranging from whether the underwriters priced the shares too high

to how well prepared the Nasdaq was to handle the biggest

Internet IPO ever — and few immediate answers.

“It was just a poorly done deal and it just so happens to be

the biggest deal ever for Nasdaq and they pooched it, that’s the

bottom line here,” said Joe Saluzzi, co-manager of trading at

Themis Trading in Chatham, New Jersey.

NASDAQ CHANGES

Nasdaq said Monday morning the changes it was making would

prevent a repeat of what happened Friday, when glitches

prevented some traders from knowing for hours whether their

trades had been completed.

The exchange also said it would implement procedures to

accommodate orders that were not properly executed last week.

A source said Morgan Stanley’s brokerage arm still had a

“large number” of share orders from Friday that were not

confirmed, which it was working to resolve.

A Facebook spokeswoman declined to comment on the share

price issue.

But analysts said that after the initial frenzy, investors

were quickly becoming cautious about the stock.

“Investors are increasingly aware of the risk embedded in

the stock price. There are real concerns about growth and

advertisers’ frequent lack of certainty how best to use

Facebook, along with rising costs and ongoing acquisition risk,”

said Brian Wieser at Pivotal Research Group, who has a $30

target on the stock.

“At $38, the stock is priced for perfection in a manner that

implied that risks were negligible.”

(Reporting By Chuck Mikolajczak, Jennifer Saba and John McCrank

in New York; Writing by Ben Berkowitz in Boston; Editing by

Edward Tobin and Maureen Bavdek)