Subject: File No. S7-24-15
From: Gordon F. Peery
Affiliation: Chair, Derivatives Practice Group, Seyfarth Shaw LLP

February 27, 2018

Dear SEC:
Thank you in advance for your consideration of the attached, which I am submitting as a comment to proposed rule 18f-4, which I gather, after a confirming call with senior SEC counsel today, remains on the long-term agenda of the Commission.
Best regards,
Gordon Peery

Gordon F. Peery | Chair, Derivatives Practice Group | Seyfarth Shaw LLP
333 S. Hope Street | Suite 3900 | Los Angeles, California 90071-1406

Copyrighted material redacted. Author cites:

Perry, Gordon F. "Derivatives Rulemaking In A New Era Of Global Regulation: Recommendations For The Securities And Exchange Commission As It Finalizes Rule 18f-4." Futures and Derivatives Law Report, vol. 37, no. 6, June 2017.