Comments of ABN AMRO Incorporated on S7-16-01

ABN AMRO Incorporated
208 South LaSalle Street
Chicago, Illinois 60604

December 5, 2001

Ms. Jean A. Webb
Secretary to the Commission
Commodity Futures Trading Commission
1155 21^st Street NW
Washington DC 20581 Mr. Jonathan G. Katz
Secretary to the Commission
Securities and Exchange Commission
450 Fifth Street
Washington DC 20549-0609

Re: Customer Margin Rules Relating to Security Futures, 17 CFR Part 41; 17 CFR Part 242; Release No. 34-44853, SEC File No. S7-16-01

Dear Ms. Webb and Mr. Katz:

ABN AMRO Incorporated ("AAI") is pleased to submit comments with respect to the rules that the Commodity Futures Trading Commission ("CFTC") and the Securities and Exchange Commission ("SEC") (collectively, the "Commissions") have proposed concerning customer margin rules relating to security futures.

We wish to note our full support for the comments that the Futures Industry Association ("FIA") and the Securities Industry Association ("SIA") (collectively, the "Associations") submitted to the Commissions on the proposed rules. As both a registered broker/dealer and futures commission merchant, AAI supports adopting a regulatory regime that would allow firms like ours to choose (or have its customers choose) between the segregation, customer protection and insolvency regime applicable to FCMs or broker/dealers.

AAI further strongly supports the proposal from the Associations that the margin policy for security futures must be adapted to fit within the existing margining regimes established for the two account types, i.e., the futures account margining regime which utilizes SPAN, and the securities margin account, which is governed jointly by application of Regulation T of the Board of Governors of the Federal Reserve System and Rule 431 of the New York Stock Exchange. This would allow dually registered firms the ability to carry and clear single stock futures products without any significant programming, operational or compliance expense or delay.

AAI appreciates this opportunity to provide this comment letter and would be happy to discuss this matter further with staff of either Commission. Should you wish to discuss this further, you may contact me at 312.855.5620.

Sincerely,

James A. Gary
Executive Vice President