Comment Text:
Dear Commissioners and other interested parties,
While I appreciate the spirit of Commissioner Chilton's proposal, I don't understand the desire to reinvent teh wheel. All we need do is look north to our Canadian neighbors. They seem to have figured this out years ago. All we need to do is copy the Canadian Investor Protection Fund. Simple. The CCC Insolvency Liquidity Facility follows in the same spirit. The key idea is to make clients whole, transfer cash and open positions in their entirety and let the fund/facility stand in the clients' place in the bankruptcy. This is far and away the best solution. The CCC has been very explicit that this can be funded by clients and the industry. The initial required capital can be quite small. Let me sum up: Let's have the humility to borrow best ideas from our Canadian friends and adopt an American version of their Canadian Investor Protection Fund.
Thank you.
Best Regards,
Peter Loos
