Subject: File No. S7-39-04
From: Raymond H. Gambel, MBA
Affiliation: Retired state examiner

February 28, 2005

THe New Board should be made up, in equal measure, of: big firms, small firms, Issuers, and the public. And the nomination process should be managed by someone who will keep the nominations and votes in a mayonaise jar on a porch and not in the custody of the redundantly discredited NASTY management and staff. Moreover, the public should exclude anyone who has worked for, or gotten significant revenue from the brokers for commercial or other services rendered.

Trust will not be restored when the crooks are on the board, the cops are on the dole, by virtue of future employment promises, and violators crimes are ignored until an indignant State Attorney reaches the point where unprosecuted violations of securities laws have passed from famous to infamous.