Subject: File No. S7-12-06
From: Steve Midlesh
Affiliation: Consultant

January 22, 2007

The Grandfather Clause is a shameful fraud perpetrated on the Investing Public. It should never have been, and the immediate removal of the "rule" should be implemented.

The SEC must enforce the Securities Acts of 1933 and 1934. The SEC lacks legal authority to change them to serve an elite group of bankers.