Subject: File No. S7-02-10
From: Thomas D Pollan
Affiliation: CEO, Pollan Enterprises

February 16, 2010

Front running / sub-penny transactions are an extreme disadvantage to independent traders who are not allowed to execute these type of transactions. I believe the "trade -at" rule would be a good first step in helping promote pre-trade public price discovery by preventing the diversion of a significant volume of highly valuable marketable order flow away from the displayed trading centers and to undisplayed trading centers.

Sub-pennying simply creates an un-fair advantage for the big broker dealers. I believe you should level the playing field and let all traders (big and small) compete equally for the opportunity to provide liquidity to the markets.