Subject: File No. SR-CBOE-2011-041
From: Martin Galivan, Mr
Affiliation: CBOE Shareholder.

May 4, 2011

In light of the the issues currently being examined in the OTC market regarding transparency and competition does SR-CBOE-2011-041 not run contrary to what is being proposed to help rectify the inadequacies in said market? While it is true that these trades will be executed on exchanges, they still are not subject to any possible price improvment by the other market participants. It would seem that this rule would bring the industry closer to internalizing order flow to the benefit of a handful of select firms while excluding a substantial segment of market participants. Obviously, if customers are being better served using this method of trade then it is a valid rule change. However, based on the information I have read, I cannot see how this improves competition in the market place. If you can clarify this in any way it would be much appreciated. Thank You for your consideration.