Subject: File No. S7-38-11
From: Olivier L. F. Asser
Affiliation: Lugano Capital Group

October 14, 2011

This new proposed regulation is deceitful, cyncial and corrupt. Neither NASDR (now "FINRA"), SEC, CFTC, DOJ, the Treasury Department, the FederallReserve, nor Congress via Special Counsel, prevented, has in now nearly two decades done a thing to deter similar conduct to the 1996 Price-Fixing Scandal, involving three dozen Wall Street investment banks and nearly a thousand NASDAQ securities. Instead, these new regulations are being enacted to in fact dissipate the rights of American citizens, for they are very specific--and thus extremely difficult to enforce in any United States District Court--rather than the extremely broad language in the Exchange Acts completely barring "Any artifice scheme or deceit to defraud." Senator Dodd of Connectiut sponsored both PSLRA and SLUSA, which gutted the rights of investors, right after 1996. He did, having quite corruptly accepted campaign financing from multiple Wall Street insitutions. This regulation, not surprisingly sponsored byu Dodd, is amazingly cynical and irrtelevant--except as an attempt to enable further fraud, rather actually enforcing existing law, they now attempt to dilute it to the point of total unenforceability. I am completely against it. Specific reasons to come.