Subject: File No. 4-602
From: Dustin Luger

July 30, 2010

As a full time proprietary for 12+ years I am concerned about the state of the market, wholly due to regulations that have created false sense of liquidity in our equity markets.

Allowing a dual tiered market by broker internalization has decimated the practice of adding liquidity for nearly all traders including myself. Add to this, the new trading halts which punish liquidity providers to an even further extent, and you are now relying solely on HFT firms and broker internalization for liquidity. As we have seen, these firms have the ability to turn off their liquidity at a moments notice to disastrous effect.

I have not seen in the media or elsewhere, discussion of the danger of the new trading halts. Due to the new speed at which stocks move in news related events, if a trader is caught on the wrong side without opportunity to close his trade prior to a halt he risks much more on that trade than originally perceived. In fact, these halts create a situation where a trader can now get "blown-out" on every single trade he enters. This situation did not exist prior to the halt rules because while he would lose on the trade, at least he would have the opportunity to exit. This has added another significant risk to liquidity providers.

Your purpose as I understand it, is to create a market that is fair to all participants, and as safe as possible for the retail public. Both of these points are being severely compromised by current market structure.

Thank you for reading,
San Francisco