April 25, 2007
I believe that the proposed changes are wholly inadequate. Except for legitimate market making activities on thinly traded stocks, (less than 500,000 shares per day) any threshold security should be required to close out all existing FTD positions within 20 days of the listing as a threshold security. This is a major problem and the SEC is going slow and avoiding true limits where possible.
If a threshold security is by definition at risk, then why be so complex?