Subject: File No. 4-627
From: Jeff Fitzmyers

May 7, 2011

You all seem to be making this as complicated as possible, and the more complex the more fraud can flourish.

A simple recipe for efficient markets:
+ Margins for everything and everybody, 90% of the notional value for the 24 hour maximum high low range for a 3 month look back period, updated every minute. That way everyone knows what the margins are, and will be. NO exceptions.
+ All things traded, and all traders, trade on a exchange, with all parties meet margin. NO exceptions.
+ Every exchange is monetarily responsible for all failures. NO bailouts. NO exceptions. NO bailouts.
+ Published bids and asks (fee, free, or delayed). No dark pools. NO exceptions.
+ For deliverables, maximum position limit of 150% of trailing 12 months of "Issued" or "Stopped" warehouse activity on all futures contracts. With a maximum 5% of open interest. NO exceptions.
+ If you cause a miss trade you pay for it in full. NO exceptions.
+ No naked shorting in stocks. All shorts must borrow stocks first, then short. NO exceptions.
+ Shareholders can denote the interest they charge to have their shares shorted. NO exceptions.
+ If any entity owns more than 1% of anything, who, what, and when, must be disclosed in realtime. NO exceptions.
+/- And if all that doesn't solve all the issues: Limit trades to 1 second intervales; once an order is entered in a market, it has to either stay for 5 seconds, or be canceled at a cost of 0.01% of the notional value of the trade. NO exceptions.

A simple recipe for fraudulent markets:
- Have PLENTY of exceptions.
- Take 6 eons to "study" or "investigate, or "test" something nebulous.
- Have 16 trillion rules that only apply to some people, some of the time, sometimes.
- Try to figure out what prices "should" be, with exceptions.
- Make sure a lot of politics and blame are involved - but only blame those who have little political power.
- And never address, nor make amends, nor make changes for something like: