Subject: File No. S7-05-12
From: Michael P. Kelly
Affiliation: CPA and Registered Investment Adviser

June 11, 2012

To Whom It May Concern"

I read the general policy on the sequencing of the compliance dates and have one comment. Oh My Godů..

This legislation was well intended and I support the principles upon which it is based. But I believe that some swap trades and practices should not be regulated - they should be banned. You can't regulate what you can't understand. I am a CPA and a Registered Investment Advisor and I don't understand half of it. It is like this is a Baskin and Robbins ice cream store but instead of 32 flavors there are 3,200.000 flavors. You have to limit the menu before you will have any chance regulating it.

Why not just ban certain types of instruments? Restrict the menu.


Michael P Kelly, CPA and Registered Investment Adviser
Life is not a Dress Rehearsal