This is a tremendously important modification to the long-standing key agreement between the two clearing agencies whose services are fundamental to the operation of the cash equity and exchange traded equity derivatives markets in the United States. The two clearing agencies have worked tirelessly on this proposal for the past several years. Based on that collaboration, and listening carefully to informal feedback from both SEC staff and staff from the Federal Reserve System, they have made important modifications to the operation of this critical linkage, to the liquidity available to both clearing agencies to provide strong assurance that the modifications will operate in a safe and sound manner in the unlikely event it ever needs to be utilized, as well as to the stress testing and systems interfaces required to continuously monitor potential mutual exposures, share information about such exposures, and make appropriate decisions in the event of an idiosyncratic or systemic failure by a large mutual clearing member. On that basis, I strongly encourage the Commission, with appropriate input from the Board of Governors of the Federal Reserve System, to grant a 'no-objection' for this proposal as well as to approve the rule changes submitted by both clearing agencies that are necessary to effectuate the important modifications to this key linkage that is a fundamental element of the system for the prompt and accurate clearance and settlement of securities transactions as mandated by the 1975 amendments to the '34 Act. Best regards, John P Davidson