Subject: File No. 265-29
From: William Silver
Affiliation: former NYSE Specialist

September 30, 2015

the recent experience with the waiving of rule 48 should be addressed immediately. It is time for a consolidated opening and closing of all markets using a consolidated limit order book. Please look at the Australia model. It is extremely transparent and impossible to game since the system freezes at random times in the 30 second period prior to the opening.