Subject: File No. S7-08-07
From: Faith Colish
Affiliation: Carter Ledyard Milburn LLP

May 21, 2007

File Number S7-08-07 - Proposed amendment of Rule 15c3-3:

I suggest that you amend paragraphs (a)(3) and (a)(4) of Rule 15c3-3 to update the references to obsolete provisions of Regulation T. Specifically, Regulation T no longer contains, as defined terms, "special cash account" or "general account." Also, 12 CFR 221 now consists of subsections 221.1 through 221.8 (excluding interpretations that begin at subsection 221.101). The reference to subsections 1 through 19 of Regulation T is obsolete.

Respectfully submitted,
Faith Colish
Individually and not on behalf of any other person or organization