Subject: File No. S7-19-07
From: James R Maikowski

July 16, 2008

SEC - Please close the loopholes in this failure to deliver issue. In this era of (forced) electronic tracking of securities it is appalling that even a 3 day failure to deliver of ANY securities is tolerated. Should a paper certificate be required delivery, then 13 days is also more than generous. After that time, the offending party should be, in my opinion, forced to purchase said securities in the open market and deliver such securities to make good on the trade settlement.