Subject: File No. S7-08-10
From: Paul G Charbonnet
Affiliation: Founding Partner, Investors FastTrack

June 16, 2010

Regarding The requirements for a computer program written in Python and XML data:

More definition is required. May I suggest additional wording, for example, "A computer program written in Python which uses the XML data to analyze contractual cash flow."

And, your proposed rules must go even further.

While XML has proposed definitions for some financial data, XML can never address all eventualities. XML which includes creative XML field names for ill-defined data is a real problem for analysts. Including a Python program would put the XML data in context of the actual computations. This is good.

Your ultimate rule MUST Also do at least one of the following, A or B

A) Define and limit the XML fields allowed. No data can be reported as "Comments". If the assets are well defined, the Python program could compute creative ways for using the asset in a portfolio.


B) If you allow creative asset definitions in the XML data, then the Python program must use this data to produce well-defined results.

A and B above describe two very different "Investments". For which kind of investment are you proposing this rule?

Paul Charbonnet