Subject: File No. S7-41-11
From: Noel Weichbrodt

October 12, 2011

1. CEO attestation is necessary for real corporate accountability. A CEO assumes the responsibility of certifying regulatory compliance in exchange for monetary & economic power.

2. Although the security risks are non-trivial, a data warehouse model should be pursued for all exchange activity due to the compelling public and regulatory interests at stake in these transactions. I would suggest that a quasi-independent entity supported by the exchange participants be established to implement security, host the data warehouse, and provide regulatory interests with verified access.