Subject: File No. SR-CBOE-2011-038
From: Kevin Baker

April 14, 2011

I would like to 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. This will cause many problems for public customers. It will create confusion and keep customers from hedging their risk.

Consider a customer who has a time spread. He is short the front month expiring option and long a longer dated option. His back month option is traded until 3:15, but under the CBOEs proposal, he would not be permitted to trade his front month option after 3:00 on expiration day. Because of this he may be prevented from taking his position off. If he attempts to sell his back month option his brokerage house would then view him naked short the weekly option, thus vastly increasing his margin. This weekly option would still appear in his account until it is expired from his account. He would have a spread that he couldnt trade out of after 3:00, but still exposes him to risk.

I would urge the commission to stop the CBOE from implementing this rule.