Subject: File No. 4-610
From: Mark J Gannon
Affiliation: Owner

May 7, 2012

As the owner of, I'm trying to find innovative ways to provide individual investors with information about fixed income investments.

The biggest obstacle in bootstrapping this business is the proprietary nature of the CUSIP numbers used to identify municipal and other bonds. Currently publishers who wish to provide a web based service including more than 500 CUSIPs most pay a license fee that starts at $10,000, and can go as high as $130,000, per year. These fees represent a very high barrier to entry and are preventing any innovation from occuring in the market for bond information.

The commission should consider replacing CUSIP numbers with a system for identifying bonds that requires no licensing fees to use.


Mark J. Gannon