Subject: File No. S7-14-10
From: Christopher C D'Antuono
Affiliation: Assistant General Counsel, GFI Group Inc.

October 8, 2010

We believe that the beneficial proxy services we receive under the current regulatory structure are accurate, reliable, and efficient. While we reserve the right to comment at a later date on the various specific issues presented in the proxy plumbing concept release, we believe the current model works well and provides us with an efficient and cost effective means to distribute our proxy materials and tabulate our beneficial shareholders voting. As you consider changes to the proxy rules, we ask you to ensure that the current levels of accuracy, reliability, and efficiency are maintained or improved upon.