Subject: File No. SR-DTC-2008-11
From: Brent welke
Affiliation: CEO, Agnova Corporation

September 8, 2008

This is window dressing. Simply enforce T + 3. Make DTCC strictly liable for double ownership repercussions. Make DTCC stockholders jointly and severally guarantee DTCC obligations. If they won't, deprive it of its special status. Then there will be no free lunch for the brokers who are facilitating share counterfeiting.

This is a problem which will solve itself if accountability is brought in.