From: Sennett Kirk
Sent: May 27, 2004
To: rule-comments@sec.gov
Subject: File No. S7-13-04


Dear Sirs;

From my perspective as a broker/dealer doing primarily retail business, I believe that a shortened settlement cycle would create far more problems than it would solve. I can see how large institutional trades might merit a shorter settlement in order to mitigate risks caused by brief and infrequent periods of extreme market volatility, but this has never been a problem in the retail end in my 25 years in the business.

The brokerage industry is broadly in favor or eliminating stock certificates for any number of reasons-some good and some self serving. Many retail customers have a very different opinion, however. With investor confidence at a low ebb, I question whether this is the time to do anything to further undermine it. I do not question the fact that certificates need to go at some point, I just question if now is the appropriate moment.

Sennett Kirk
Kirk Securities Corporation