Subject: File No. 4-606
From: Amy L Young, CFA
Affiliation: CFA Institute

March 27, 2013

I continue to believe the securitization market - especially with electronic trading - is a system that has exploded into an unethical system. I tried to patent a valuation methodology that takes the buy, sell, hold decisions out of investment banks and into the hands of people who touch the company. You are welcome to look at the software, if interested.

Bottom line, I don't think the SEC can stop the inbred system of insider trading, it is Soo pervasive and makes market values truly meaningless.
I believe the system will fail at some point and methodologiessimilar to mine will need to be in place to unwind the trading. Private equity firms value better than public markets.

As an analyst on Wall Street from 1996-2008, I had to do so much guess work, and with SOX, getting a feel for qualitative and quantitative data from employees and other sources was difficult.

I now look at valuing land and see the numbers and can model and project with better accuracy.

I truly believe in ethics and the CFA was THE BEST at providing the framework for what is ethical in the securities industry. Like the Series 7 is required, so too should an ethics exam be required by everyone in investment banks that makes sense.

I have taken real estate courses and NY state exams, and the law is an important component. It should be so that every transaction is fair and reasonable and a duty of care is given. Confidentiality is stressed for material non public information....and this is the hardest one....which. Is why a private equity model will ultimately prevail with SBA loans from banks. The key will be how to preserve the principal for hardworking people who have pensions, 401ks, IRAs etc.

I am hopeful that the SEC can help unwind the securitization market successfully as the FDIC quickly assists failed banks. If my software could help start the foundation, I would be happy to show the SEC what is GLobal Institute of Finance and Trust. I will give you the software. You have my email.

Ethics are critical to help minimize the insider trading....and the basic code of conduct in the securities business.

Hope someone reaches out. Many companies liked my approach - they just depend on Wall Street for money, so they were afraid to try it - General Electic. Disney and Nestl also liked the way that corporate responsibility, sustainability, ethics, all played a part in the value....not just net income. I have all the responses from companies who liked it.

Regardless, the CFA Institute taught me the difference in right and wrong on Wall Street. I left because of the corruption. I get the SEC emails and I see your progress. You do great work Best of luck...if I can help in any way, please let me know. I believe in sustaining the world - providing clean water - and now after analyzing real estate and working with horticulturist, farmers, landscapers, gardens, peconic land trust, I have turned to understanding how land is won't be an invisible security that will save the world, it will be feeding the world with the land we have and providing homes for all and food. The community banks get it. Small and simple. The securities market that inspired the industrial revolution has become warped with the Internet....I believe in altruistic isn't so much profits but is a company good to its people, the community, the world. Securities to survive need to change from greedy mind sets to giving ones. To give is the greatest gift which is why I created GIFT because I really want a financial system that always preserves principal. Interest/dividends or capital gain should be inflation. Ultimately, a finance system where savings are only government bonds would be better than our complex market.

Sorry for the lengthy note. Please keep anonymous and confidential - never to be disclosed beyond appropriate government officials. Thank you.