Subject: File No. S7-27-10
From: Townsend Walker
Affiliation: Economist/Writer

October 15, 2010

The cap of 20 percent on voting rights is too high. Three entities with that percentage control any vote two entities would unduly influence a vote. I believe the cap should on the order of 5 percent.

Exchanges and clearing houses are public goods and should not be able to be overly influenced by a few interested players.