Subject: Comments for File Number S7-12-11

May 22, 2011

The goal is to assure that banks don't profit by market manipulation or fraud. One idea to discourage market manipulation would be to block bank employees from selling their stock options until ten years after they leave the bank. They might then hesitate to take big risks. Their involvement in a fraud admitted by the bank, even through a non-prosecution agreement, could cause the stock options to be forfeit. That would discourage fraud.

These ideas could complement other suggestions, such as adjusting bonuses based on the bank's safety index.

Richard Stallman