Subject: File No. 4-639
From: David Lopez
Affiliation: Spartan Securities Group Ltd.

October 13, 2011

Hello,

I have listed topics for discussion as follows:

  1. NSCC illiquid fee - the fees direct detriment to small businesses' ability to raise capital and have stifled shareholders access to liquidity.
  2. DTCC placing "chills" on deposits - adversely affecting shareholder ability to access liquidity in the open market.
  3. DTC not allowing OTC securities access to FAST (DWAC or DRS services) - though FAST is mandatory for NYSE and NASDAQ securities.
  4. FINRA audit activity and communications - brokerage firms now no longer allow micro-cap securities to be deposited by shareholders.

Thank you.

Best regards,

David Lopez
FINOP
Spartan Securities Group Ltd