Subject: File No. 4-605
From: Bob Leonard
Affiliation: Metro Stamping

November 28, 2010

"These are comments in regards to a petition for rulemaking change,"


Clearly this an idea who's time has come. I understand and appreciate the need for SEC 'watchdog' activities and fraud prevention but surely the benefits here outweigh the risks.

This is a crucial time in American history to experiment with innovative solutions to the (capital formation) plight of (very) small business.

Thank you

Bob Leonard
Metro Stamping