Subject: File No. S7-12-06
From: Phil Bennett
Affiliation: Former Refco CEO

September 6, 2006

Gentlemen, First let me say how appreciative I am for your organization. To be honest, when you listened to the tapes of Rhino traders telling my brokers to "crush Sedona" I didn't think you'd let me take my company public. But, as usual you sided with the Investment banks who made a killing on our IPO over the investing public. For that, I'm grateful. This Rule 3210 is yet another example of the SEC paying lip service to individual investor concerns about transparency. It was supposed to go into effect in July. For those of you not familiar with Rule 3210, it was to extend short interest reporting to ALL OTC securities. According to there are dozens of small companies with very large short positions yet NASDAQ shows no such positions. More Rules ENACTED but not ENFORCED. By SEC standards, you all deserve a raise. Nice work if you can find it. Almost as nice as the BOAT LOAD of money I milked Refco for after you let it go public. You will always have a friend in Phil Bennett. Cheers