Subject: File No. S7-02-10
From: CHRIS BANYAI, CFA
Affiliation: President, BANYAI WEALTH MANAGEMENT

April 5, 2010

The NBBO is the most vital aspect to a fair and orderly market. Over the past year or so the NBBO has become virtually unattainable and at moments unknown. The practice of sub-pennying, flash trading and dark pool orders has tilted the playing ground advantageously to the chosen few allowed to play by their own rules. As a professional equity trader of over six years my living is based on providing liquidity to the market. In the past few years I have traded well north of 50 million shares. Over the past 6-8 months my volume has fallen off a cliff. I believe I am not the only professional stock trader that this is happening too. When an industry is faced with a monopoly or oligopoly competition is considered unfair and drives others out of the market completely. This is the scenario we are inflicted with currently. The major players have such a substantial advantage through there evasive stock buying and selling activities the industry is dyin
g. A day will eventually come that liquidity will be dearly needed. What happens if in the time of need the major players hit the off switch on there mega computers? I hope and pray that day doesn't happen