Subject: File No. S7-35-11
From: John J Faust, Jr
Affiliation: Retired

September 3, 2011

Comments attached: It is my considered opinion that the SEC is "barking up the wrong tree" and should not make any changes to Rule 3a-7. It made sense when it was implemented and I see no reason to make changes. I strongly urge the SEC to abandon this endeavor.