Subject: File No. S7-08-07
From: Gene L Finn, Ph.D.

September 17, 2012

In earlier comments, I have requested that 15c3-3 be modified to require brokers, executing customer trades as principal, to sweep cash to the customer sweep account no later than next day (T+1).

In letters to the SEC, I have recommended requiring a change from the SEC prescribed settlement of T+3 to T+1.

Until that occurs, individual retail customers are exposed to unnecesary risks that may not be covered by SIPC in the event of an executing broker failure.

For example, assume that the customer sweep account is in a customer mutual fund money market account and a sell trade occurs for over $100,000, the SIPC limit of cash coverage for such customers. The customer is exposed to losses for two days, unnecessarily.

It appears that, SIPC, (see SIPC letter dated May 17, 2007 in this file) limits coverage of cash in such cash accounts (those with customer mutual fund money sweep accounts) to $100,000.

It is common for cash accounts to have sales aggregating more than $100,000 in cash, sequestered in marketmaker accounts for 2-3 days, merely because an SEC policy has fallen behind the times.

Other countries have moved to T+1 settlement.

Respectfully yours

Gene Finn