Subject: File No. S7-06-08
From: daniel w roberts
Affiliation: elected member, western region, finra small firms advisory board

May 12, 2008

-i suggest that the sec regulatory action in this case exceeds the mandate contained in the 1933 and 1934 acts which spelled out the prime objectives of this oversite commission. proscripted rules such as are put forth via this request for comment are best left to the industry sro which should be better equipped to interpret the the need for rules , especially as they affect the smalled firms. time after time sec rule making is adverse to the best interests of the financial industry, the smaller firms and the public as a whole. please follow the intent of the tenth ammendment so as to let the states an or the sro perform the rule making as appropriate. i know you feel a vacuum at this time but please do not feel that you must act to fill every vacuum.