Subject: File No. SR-FINRA-2010-055
From: Gary S. Sheller, CFP
Affiliation: Sheller Financial Services

November 24, 2010


I am writing to comment on the issue of determining the "triggering event" for the activation of a stop order.

I feel that the determining "event" should be an actual transaction taking place at the particular price that the stop order is based upon. An offer or bid is only one-half of a transaction, someone must be willing to accept that offer or bid in order for a "trade" to take place and the price thereby properly established.

To activate a stop order based solely upon a bid opens the process to manipulation by those inclined to do so by flashing bids during market turbulence.

Thank you for your consideration of my opinion.

Gary S. Sheller, CFP
Sheller Financial Services