Subject: File No. S7-03-10
From: steven vannelli

May 28, 2010

I agree with the concept of this rule change. In addition i believe that firms, organization or individuals that use a members "ID" should 1--be registered as either a b/d or RIA 2-- have minimum capital at least equal to a portion of the assets they control. For the firms that do allow their "IDs" to be used there should be a mechanism that makes them liable for costs and expenses arising from a failure on the part of the user.

Finally, anyone using a brokers "ID" should be strictly prohibited from naked shorting. If they engage in this type of trade they should be fined for the first violation and disallowed from using the brokers "ID" for the second viiolation. Moreover, sanctions against the broker of anyone using their "ID" and engage in naked shorting should be part of the rule.

Thanks You

Steven Vannelli