Subject: File Number S7-20-08

July 25, 2008

There should be no relief from 15C3. Lets think for a moment why a broker would be in deficit. Only one way his requirement increases (Long) all seg calculations are done on a settlement date basis. Keeping that in mind the only thing causing the deficit is that something is short such as Fail to Receive or CNS, short account customer or firm, or the a broker has a Stock Loan outstanding. Anything but the Stock Loan (which would dry up simply because the status of the margin customer changed reduced debit, increase in market value etc or the firm sold out of it proprietary position) The other three remaining open entities means you had a problem in the first place (except for the market maker).
Why not just take all the securities in question and put them on a special threshold list and reduce the 13 day requirement….