Subject: File No. S7-12-06
From: Russell A. Ulibarri

April 7, 2007

The "Grandfather Clause" should be removed immediatley. This is a ruling that should not have been placed in the first place. To have this ruling in affect is a travisty to the average investor. When one purchases a security it should be delivered and not left "open" Rules and laws are in place for a reason and allowing anyone to "get away" with breaking the rules is just wrong.