These comments pertain to the proposed rule change on Margin.

The proposed rule changes should not be adopted for the following areas:

4:1 Margin
New Call Calculation to Include Aggregate Trades For The Day
Meeting Calls Immediately
Money Timing

The primary purpose of the proposed rule change is stated to be the control of risk for trading. Unfortunately, the proposed rule does not accomplish this task and in fact will increase risk for some while being purely punitive to experienced traders.

The proposed rule increases margin to 4:1. This would allow inexperienced traders the ability to open stock far in excess of current amounts. I believe that this is not in the best interest of the trader or the brokerage firm (Who is responsible for accounts that may go negative.)

For experienced traders the rule is punitive. An experienced trader usually has money in interest bearing accounts to cover day trading calls that may arise. The proposed rule intentionally hurts active traders by changing margin call calculations to include all trades for that day. This is totally contrary to the stated purpose of the rule change. Traders may enter and exit positions several time during the day. This in and out movement actually reduces the trader's risk by allowing the trader to take small losses with the ability to reenter the position or reverse position. The proposed rule yields an incentive to hold a position to reduce the potential for a margin call.

In addition, it does not make sense to calculate margin calls on the aggregate of trades for the day. What does that have to do with money used. The only logical margin call calculation would include the highest amount of capital used at any given time.

Traders need time to arrange for money transfers to cover calls. The proposed rule is not realistic and is punitive to traders and investors. In addition, the rule will not reduce the risk to traders; it will force traders to be less diverse by pooling cash in my trading account. This will leave less money for long term investments thereby increasing my overall risk.

As a successful day trader with several years of experience, I firmly believe that the proposed changes would increase risk to traders and should not be adopted.