Subject: File No. S7-16-06
From: Jeffrey B Broadhurst
Affiliation: MBA, CFA, CFP

October 31, 2006

The proposed changes would be welcome. If adopted, they are a good thing for the integrity of the industry, especially
1) changes to the net capital rule more reflective of current levels
2) amendments to standarize provisions of subordinated debt agreements
3) and amendments to bolster the early warning provisions.
I would support such changes.