Subject: File No. S7-26-10
From: Glenn L. Boom

October 13, 2010

I suggest a better method would be to develop a sliding scale related to the amount of derivitives the bank holds or seeks to hold that would increase their capital requirement. Also, include the provision that the bank would not be considered "too big to fail" and have a mechanism available for a take-over of the bank when it moves into troubled waters.