Subject: File No. S7-19-07
From: Robert Almy

August 22, 2008

The OMM exemption needs to be eliminated. It is unreasonable, arbitrary and capricious in the first place and to let it continue is a miscarriage of justice.

Further, The Office of Economic Analysis (part of SEC) issued a memorandum June 9, 2008,


Which states in pertinent part:

"In summary, the results indicate that fails to deliver in non-optionable securities declined significantly after the elimination of the grandfather exception while fails to deliver in optionable securities increased significantly."

Both of these facts (SEC findings and conclusions) contradict all claims in support of the OMM exemption. As Dave Patch pointed out the protestors of changing the OMM exemption have not produced any empirical data to support their claims or to counter the SEC findings that fails to deliver in optionable securities continue to increase significantly.

T+3 for every one and a locate rule that requires verified proof of borrowed stock with the actual owners knowledge and consent is necessary.