Subject: File No. SR-CBOE-2011-038
From: Kenneth Casper

April 13, 2011

I would like to strongly object to the CBOEs proposed rule change File Number SR-CBOE-2011-038.

The CBOE is requesting that trading should be halted at 3:00 instead of 3:15 for Weekly and Monthly index options. They claim the purpose of this change is to eliminate confusion and protect the public interest. This change will do neither and will in fact increase confusion and go against the public interest.

Although the stocks that make up these indexes generally stop trading at 3:00, THE INDEXES VALUES CONTINUE TO CHANGE WELL PAST 3:00. It is common to see changes to these index values as late as 3:05 and sometimes much later. Customers will no longer be able to hedge their risks by trading these options, even as the underlying index is moving after 3:00. This is a huge detriment to the public as it limits their ability to manage their risk.

The claim the CBOE makes that this change will eliminate potential confusion is ludicrous. The public has been accustomed to trading this product until 3:15 since its inception. A change to 3:00 will create confusion. A customer who has a position will no longer be able to exit this position after 3:00 even though it may be gaining or losing money