Subject: File No. DF Title II - BD Liquidation
From: Donald M. Feferman, Esquire

October 18, 2010

Introducing brokers with little or no capital or insurance are permitted to engage in a business that often costs their investors millions of dollars in losses. Often the losses are the result of fraudulent actions by the introducing broker. I've been arbitrating securities cases for over 22 years. The number of judgments rendered by arbitration panels against these types of operations that then go out of business without bearing any responsibility for the damage caused is legend. It's criminal to allow anyone to be able to subject his customers to such risks without sufficient capital or insurance.