Subject: File No. S7-08-09
From: Howard F Ward, CFA
Affiliation: Chief Investment Officer, Growth, GAMCO Investors

April 24, 2009

My investment career spans 31 years. 4 years with Brown Brothers Harriman Co., 12 years with Scudder,Stevens and Clark and 15 years with Gabelli Asset Management (GAMCO). My feeling is that in a general sense the trading community has pretty much dominated the regulatory arena for some time. It seems as if rules were relaxed with the objective of increasing trading volumes and the kinds of securities that could be created, sold and traded. Usually arguments were made to increase liquidity, transparancy, hedging or avoid loss of business to foreign markets without such restrictions. During this period of many years of deregulation, the desires of smaller investors and longer term oriented equity investors were not at the forefront. We have now frightened away many of these investors who have tradtionally formed the foundation of our capital markets. The uptick rule should come back. Naked short selling should be banned. Capital ratios should be increased. Credit default swaps should be regulated. The role of leveraged ETFs should be examined. Make the market safe again. We don't need more "liquidity". Thanks.