Subject: File No. 4-581
From: Diane G. Lankford
Affiliation: Retired 40 year Nationally Recognized fixed income investment banker

May 29, 2009

-Absolutely opposed to past elimination of the up-tick rule.

Re-institute the up-tick rule at a minimum of 1/10th.

Absolutely opposed to naked credit default swaps.

Limit such BOND INSURANCE to contracts between the actual bondholder and the insurer under appropriate reserve requirement and regulation. So called, credit default swaps owned or for the benefit of other than the holder of the credit so insured ("naked") are no different than the loans such as the Mafia made in the 60s 100% secured by insurance on the life of the borrower payable to the lender.

Eliminate and severely penalize any form of naked short.

Stop kidding yourself that hedge funds should have different margin rules and requirements than all other accounts. If the margin rule for me is 50% it must be the same for hedge funds.