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Comment for Proposed Rule 75 FR 76706

  • From: Kimberly Kahl
    Organization(s):
    Former Whistle-blower

    Comment No: 26663
    Date: 12/9/2010

    Comment Text:

    I am Mute due to Cervical Dystonia a form of Parkinson's Disease so if you must call please leave a POC contact email address.

    As this is the third time I have tried to transmit comments regarding the proposed rules I will not be retyping the questions but rather only answering them by number:

    subject: ALGORITHMIC STUDY
    AGAIN:

    15. I USUALLY ADAPT THE PROGRAM BEING USED BY THE CURRENT HOLDER OF THE DERIV ATIVES.
    16.YES, THERE MUST BE INTERNALLY ARCHIVED VERSION OF MESSAGES WHICH CONTAIN PROPRIETARY CODE SHOULD BE ENCODED.
    17. YES
    18. YES, BUT THEY MUST BE BACKED UP AND COPIES STORED FOR ANALYSIS AT AN ALTERNATIVE LOCATION
    19. By me to interested parties for tracking and analysis
    20 YES, all life cycle event changes must be confirmed by more than two parties and when a derivative contract is changed all parties MUST be notified.
    21. No Comment. It should increase frequency, reduce misunderstandings of complex contract terms and increase ease of trades.
    22. It can e if the data is accurate and truthful. Previous exposures of anticipated net gains and losses in compariable complex net derivatives.
    23.XML - EXPANDABLE MARKUP LANGUAGES are only useful with a previously described derivative - the problem occures when data languages are changed and are not compatible or frward and back ward compatible.
    24. No comment
    25. No
    26. Yes
    27. Yes, but it would also make financial derivatives easier to manupluate
    28 If the standarized computer readable descriptions are not encoded it would enable hackers to back-end manupluliation of end run data. Yes.
    29. No comment
    30. See best practices. What has worked in the past it has to be a combined effort.
    31. Ontologies can only work if the data is monitored and processed accurately, the information when setting up ontologies needs to be accurate and the process should be flexable enough to allow for refined reporting access.
    32. yes, when working for the government we changed from a CTOS based system to a DOS system and then back to a CTOS system.
    33. Considering they have changed back to a DOS based system it only created more difficulties for programers not fluent in administration of the language being used.
    34. Settle on standards easily recognizable and then encode them.
    35. Very useful, but without using an encoding or decoding script it would endanger the entire financial industry.
    36. Very carefully!
    37. yes
    38. Finger print access for signature authority and or some type of id card system
    39. All contract information needs to be shared by all parties involved in the contract negoation.
    40.Yes, it would stabilize the derivatives market and enable ease of trade but unless the laws are clear on the penalities involved for fraud it will increase useage of Computer Systems to scam and con investors. Thank you for the opportunity to comment on this important up comming legislation.

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