Subject: File No. S7-19-07
From: Michael W O'Boyle

August 13, 2007

There should be no loophole for the options market maker.

All loopholes do is permit criminal abuses and misunderstandindgs.

A perfect example is NFI. The OMM rolls over contracts every month ever increasing the numbers of options contracts.

I don't want or need the kind of liquidity that loophole permits and the United States shouldn't want or need it either.

It is formalized theft ontravening basic supply and demand economics which permits financial terrorism when real shares do not need to be located in a timely manner (3 days).

The trading standard for settlement should be the same for all participants.

There should be more transparency and information regarding trades particularly with FTDs available to the market. Investors should be able to learn where persistent FTDs are originating.

Bi-monthly reporting was a step in the right direction.

I would like to see weekly reporting using Wednesday mid week data regarding trades as most shorts close out there positions on Friday.

I have no trouble with an investor pursuing a short strategy when they acquire real shares legally with the exception of OMM counterfeited shares and FTDs.

As an investor when I make a trade for purchasing shares in a company I have to pay for the transaction.

Investing in the stock market has enough risks. How is it possible that I can end end up not owning shares in the company I just purchased in a legal market transaction? With any other good several crimes would have occur for that to happen.

How about a little more transparency and information to the investing public?

The SEC has a tough job but it gives the appearance of failing to act responsibly to protect the private investing public it was created to protect.

The uptick rule was implemented for a good reason.

Consider how speedily the uptick rule was eliminated and the effect it has had on stock market volatility.

Compare it's implementation of REG SHO and removing the OMM exclusion which would benefit the private investing public.

Please do the right thing and eliminate the OMM exception and keep the big players honest by enforcing the existing laws on the books.


Michael W. O'Boyle