Subject: File No. S7-12-06
From: Joseph A Angel
Affiliation: CEO, Diogenes Services LLC.

March 29, 2007

There should be no question that the Grandfather clause should be immediately removed. I suggest that the SEC et al. contact every company that has 401k investments, as well as other pension retirement payroll deductions, and inform all of the participants of these retirement accounts exactly what is the Grandfather clause and regulation SHO. Perhaps the kings horses and the kings men would be overworked at that point. The excuses that the market participants, watchdogs and regulators postulate regarding the mysterious "Fail to Deliver" is absolutely ludicrous at best. This is an opportunity to fix the problem gracefully and allow the egg shell to fall where it may.