Subject: File No. S7-21-09
From: Norman P Quinn

July 8, 2010

I have been a broker and a trader for over thirty years in mainly fixed income and futures. "Flash Orders" are nothing more than front running..pure and simple. They provide liquidity in the same way front running provides liquidity. At the expenses of the customer and to the benefit of the front runner.

Also, you should look in to the computer programs allowed to run on CME/CBOT products... such as "icebergs" which hide true market size. Also, the "clogger" programs...which allow an entity to offer or bid for a large amount of futures contracts, but cancel a sizeable portion of the order if an order comes in to trade it before the contra-party can get filled. I.E. 20,000 bid...orders comes in to sell 20,000, but only sells 5,000...that is false and misleading. As are icebergs. Block trades should also be allowed in all markets or none. They are disallowed in certain spreads and commodities at the whim of the exchange management for the benefit of special interests...customers and members. Good got a lot of work to do to clean up the messy and corrupt culture fomented over the last ten years... Thanks, Norman