Subject: File No. S7-38-11
From: suzanne h shatto

October 8, 2011

why make a rule that will be difficult to enforce, that has exemptions that are very liberal?

i don't understand why the market MUST have derivatives in the first place. aren't ETF's and options enough? do you have to have these secret gambling instruments that may or may not be disclosed to the participant's investors?

i think the SEC needs to rethink all this idea about hedging.

and the SEC had better think about how to measure risk, how often to measure risk.

the more complex, the less understandable.