Subject: File No. 265-28
From: Christian B. Rafool

September 27, 2012

Dear Members of the Committee,

I am submitting this letter to you in order to present a solution to the risks associated with High Frequency Trading that will restore retail investor confidence in our stock markets/exchanges.

The speed of trade must be brought down so that investor rationality is not manipulated or overwhelmed but rather restored so that order, confidence and trust is restored in the markets/exchanges. The solution is easy and time tested. It involves doing three things together. They are as follow:

1.) Bring back the quotation of stocks in fractions or at a minimum in "nickel" increments rather than pennies.
2.). Bring back the "Up Tick Rule".
3.). High Frequency Trading according to them and most if not all exchanges increases the liquidity and depth of the market. This is perceived by them as being a benefit and crucial. Since it is crucial, the High Frequency Trading firms should not be able to walk away from the market leaving an immediate vacuum should they desire. The firms should be held to newly created rules that are similar to the rules of market specialists.

The first two can be done immediately and will have virtually no cost to the average retail investor accept for possibly a few pennies per share, which is a small price to pay for reducing volatility, risk and fairness. Both measures were used for many years without the issues faced today. The average investor asked for better execution prices and commissions, but never asked for multiple and historic sessions in the market moving be multiple percentages and hundreds of points. The retail investor generally feels the market is rigged rather than the market's pursuit for low cost brought a worse by product of extreme volatility. The pendulum just swung to far, and needs to be brought back.

I ask the committee to think logically and with common sense by restoring these time tested measures and adding the new one with regards to rules for High Frequency Trading. It is time to restore and send all the white paper, theorists, and geeks with formulas packing.

Thank you for your quick attention and action.

Christian B. Rafool