text:
October 3, 1997
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, DC 20549
Attention: Mr. Jonathan G. Katz, Secretary
Re: SEC File No. S7-16-97
Ladies and Gentlemen:
Bloomberg L.P. appreciates the opportunity to comment on the Commission's Concept Release on Exchange Regulation, Securities Exchange Act Release No. 38672 (May 23, 1997). Implementation of the policies suggested by the Release would affect Bloomberg's business and therefore we take a special interest in the matters discussed and suggested.
Bloomberg is engaged in the business of providing its customers with financial market information, news and analytics via its worldwide electronic network (the "BLOOMBERG service"). Bloomberg also services its broker-dealer and institutional customers' communications needs and facilitates their transaction of business by offering various additional services, including electronic messaging, non-anonymous offerings, bids wanted and Financial Information Exchange-protocol ("FIX") equity order-routing and indications of interest. More than one and a half million text messages and several billions of dollars of securities transaction messages are sent and received by Bloomberg customers across the BLOOMBERG service every business day.
As the Commission knows, under the current regulatory framework, alternative trading systems ("ATSs") for equity securities generally have had to organize as broker-dealers. For that reason, when Bloomberg established a proprietary electronic anonymous trading system (the "Tradebook System") in 1996, we organized a broker-dealer subsidiary, Bloomberg Tradebook LLC ("Tradebook"). Tradebook registered with the Commission and joined the National Association of Securities Dealers, Inc. (the "NASD"). Bloomberg and Tradebook also contracted with two unrelated parties to provide execution and clearing services to the Tradebook System: B-Trade Services LLC ("B-Trade Services"), an affiliate of ESI Securities Company ("ESI"), executes trades of the Tradebook System and ESI clears and settles the trades.
Through the Tradebook System, Bloomberg offers its institutional and broker-dealer customers, and other broker-dealers that access the Tradebook System via SelectNet, the opportunity to buy and sell equity securities via the BLOOMBERG service. Within the United States, Bloomberg also provides its customers with access to the Arizona Stock Exchange. Outside the United States, Bloomberg provides to institutional customers and others the ability over the BLOOMBERG service to trade on Tradepoint Investment Exchange. 1 In addition, we expect in the future to provide access to additional points of liquidity as customer demand dictates.
Since it has always been Bloomberg's intention that Tradebook not engage in traditional brokerage business, but rather act as a broker-dealer for limited ATS purposes, Bloomberg is open to suggestions about changes to the regulatory structure of ATSs. If the Commission revises the current regulatory framework to better suit the types of services ATSs provide, and to do so without restricting the ability of ATSs to compete aggressively with other economically similar service providers, it would not particularly matter to Bloomberg whether Tradebook is called an exchange or a broker-dealer.
General overview. The Commission's focus on the issues presented in the Release is timely, well needed and appropriate. Technology and the growth of electronic markets have changed the trading landscape irreversibly. The Commission is absolutely right to raise to public debate questions about whether its regulation should be revised, even substantially, in response. To a large degree, the reputation of the U.S. securities markets for reliability and fairness is a direct result of the Congress's legislation, and the Commission's regulation and surveillance of the markets and market participants during the six decades since the enactment of the Securities Act of 1933 (the "Securities Act") and the Securities Exchange Act of 1934 (the "Exchange Act"). Regulatory initiatives to combat abuse have helped to provide an environment in which market forces have cultivated efficiency and innovation in the financial markets and in related services.
The Commission's recent adoption and implementation of the Order Execution Rules 2 have had a dramatic effect on the markets. By requiring greater transparency and integration of and greater access to the public and private markets, the Order Execution Rules appear to have rapidly achieved their direct intended result: better order execution for customers.
An unanticipated, ancillary benefit to the Order Execution Rules has been the unleashing of new competitive forces in the market relating to ATSs. The new rules allow a complying electronic communications network ("ECN"), which is a type of ATS, 3 to publish its best prices for Nasdaq securities in the Nasdaq quotation so that these prices may be available to all investors. We understand that this opportunity for new ATSs to widely disseminate their quotations and receive order flow from NASD members has lowered the principal barrier to entry and encouraged several new competitors to enter the ATS field. While there is some evidence that market makers may be reducing the numbers of stocks in which they will make markets, in the main the new requirements have been beneficial to investors since they have promoted market efficiency and given the public better trade executions.
As a result of the Order Execution Rules, for example, the Tradebook System's "top of the file" is a matter of public record on Nasdaq (except where non-market makers themselves, in entering orders directly into the Tradebook System, have opted that their orders not be displayed, as permitted under the Order Execution Rules) and can be accessed via SelectNet by all NASD members on the same basis as is available to Tradebook participants.
One question the Commission faces is whether, and to what extent, to regulate market structure by affirmative Commission regulation and when, and to what extent, to allow natural market forces to act as the regulator. In some cases, we believe, the balance shifts decidedly in favor of Commission regulation, as was the case with the Order Execution Rules. In others the balance should shift the other way. For example, while we believe the Commission is right to be concerned about issues such as market-wide ATS system capacity, we also believe that the Commission need not, under current circumstances, regulate specific system capacity and reliability issues with respect to ATSs because competition will likely provide sufficient impetus in that arena.
It is precisely as a result of the competition unleashed by the Order Execution Rules that there are now alternatives in the market to any single ATS or market center. We believe any concerns that exist in the marketplace about ATS capacity and reliability represent a commercial opportunity for new competitors such as Tradebook. We are confident that the free market will order the capacity and reliability it needs.
We have concerns, however, regarding the marketplace and the regulatory status of ATSs that were not addressed specifically in the Release. As the Commission is aware, in order to offer the ECN Alternative 4 under the Order Execution Rules to market makers and specialists, an ECN must accept non-participant broker-dealers' orders for execution against orders in the ECN that are publicly displayed, in a manner equivalent to broker-dealers' accessing market-maker orders not displayed in an ECN. In practice this means a complying ECN must provide telephonic and electronic access for non-participant broker-dealers.
Since January 1997, "compliant" ECNs under the Order Execution Rules have provided electronic access to non-participant broker-dealers through the SelectNet order-delivery system operated by The Nasdaq Stock Market, Inc. ("Nasdaq"), a method that places ECNs at a technological disadvantage. Currently, an ECN that executes a SelectNet order cannot bind the order-entry firm to the execution unless and until the ECN has received from SelectNet an acknowledgment of the execution message. Bloomberg's private connections to its customers contain certain safety features such as automatic re-transmission of messages, but the SelectNet technology does not permit an ECN to re-transmit automatically an execution message when SelectNet has not immediately acknowledged the ECN's notice of execution. As a result, when a notice of execution from the ECN back to SelectNet is delayed or lost and the order-entry firm permissibly cancels the order, an order mismatch occurs and the ECN becomes responsible as a principal to its participant for the trade.
To avoid the current disadvantages inherent in Nasdaq's communications systems and the resulting exposures to multiple trade executions, we believe that each market center should be wholly autonomous of all other market centers in receiving and executing orders. Competing market centers, including ATSs, should each be able to contend for participants and order flow on the basis of cost, service and innovation. Under this market structure, institutional investors and broker-dealers would not be dependent on any single market center. We believe technology has made the model of competing market centers an achievable reality and that technology and competition among marketplaces together have the potential to provide an array of additional benefits to market participants and the market as a whole. 5
In addition, Bloomberg believes that, among competing market centers, each market center should be able to deliver an order to another for execution against the other's displayed order. The receiving center should in turn be able immediately to execute that order, or decline it if its displayed quotation has already been filled. The receiving center should not thereupon be dependent on the delivering center to confirm acceptance of the completed trade.
An even greater problem arises from the fact that SelectNet apparently takes, on average, three seconds to deliver a response from an ECN back to the order-entry firm. As a result, although ECNs must, and Tradebook does, respond immediately to non-participant SelectNet orders, the three-second delay has led to complaints by order-entry firms. We understand that a response is currently under consideration that, if implemented, would be truly anti-competitive.
This response would be to allow Nasdaq to send execution messages, rather than orders, to ECNs in the same manner as the Small Order Execution System currently operates. While this would decrease response time for non-participants, it would centralize distribution of order executions and force ECNs both to abandon strict time priority and to prefer non-participant orders over participant orders, in order to avoid the risk of double executions. While non-participant orders would be matched against the ECN's published quotation in Nasdaq and executed immediately, all participant-to-participant matches in the ECN itself would have to be frozen and not executed until the related published quotation in Nasdaq could be withdrawn and confirmation of the withdrawal received. That disparity would effectively destroy ECNs because Nasdaq would offer better access to non-participants than ECNs could offer to their own customers. 6
We believe there is a better solution. We recommend that the Commission establish a standard for directly connected non-participant access to ECNs. ECNs meeting the direct-connection standard would be deemed to provide "fair access" under the ECN Alternative. The standard could require providing direct access via a dedicated communications link at the request of the non-participant, together with software that the non-participants could use to send orders to the ECN. 7 ECNs that chose not to offer direct connection would have to accept execution messages from Nasdaq, making Nasdaq the single market center with respect to those ECNs while eliminating the three-second delay.
ECNs that chose to offer direct connection would provide order access, without the three-second delay, to any non-participant who elected to receive a direct connection. Those ECNs would continue to receive order messages from non-participants who selected Nasdaq as the access provider rather than using a direct connection. These non-participant order messages, would, of course, continue to be treated equally with participant orders. Providing that choice to ECNs would solve the three-second-delay problem without creating an inherent advantage for Nasdaq and also would solve the problem of lost messages. 8
ATS regulation. ATSs are at once similar in a few respects, and dissimilar in many respects, to both traditional broker-dealers and traditional exchanges. An ATS resembles a broker-dealer principally in that it effects transactions for institutional customers. Unlike a traditional full-service broker-dealer, however, an ATS need not carry customer accounts, commit its own capital to make markets or execute trades, engage in underwritings, or provide research or recommendations to "customers".
An ATS is like a traditional exchange in that it provides an economic forum for its users, including broker-dealers and institutional investors, to interact directly with one another. Like an exchange, an ATS adds value to the marketplace as an aggregator of orders. Unlike an exchange, however, an ATS also is in the business of providing service directly to institutional investors. In contrast to an exchange, which typically is a membership, non-profit organization, an ATS is a private, non-membership, for-profit entity.
While ATSs are not accountable as a matter of corporate governance to their participants, nevertheless they are accountable in a commercial sense. If a user of an ATS believes it is not fairly represented or if a prospective user believes it has been denied fair access, they each have the ability to select a competing ATS. Tradebook views issues of fair representation and fair access as commercial opportunities, and we aim to build a business on the demand in the marketplace for alternatives among alternative trading systems.
The Release proposes two alternatives for regulating an ATS: either as an exchange, with certain exemptions from the traditional definition of "exchange", or as a broker-dealer, with increased responsibilities and perhaps a new SRO. Bloomberg is more concerned about preserving Tradebook's ability to respond rapidly and with creativity to the demands of our customers than it is about a change in nomenclature or category of regulation. Given that premise, we would like to comment on the advantages and disadvantages of the proposed approaches and certain specific questions raised in the Release.
Certain benefits would accrue to the market and to ATSs if ATSs were to be reclassified as exchanges. Trading by New York Stock Exchange ("NYSE") and American Stock Exchange ("Amex") members on an "ATS exchange" presumably would be exempt from the off-board trading rules, NYSE Rule 390 and Amex Rule 5, providing greater trading flexibility to NYSE and Amex members, increased liquidity to ATS participants and enhanced competition between and among markets. In addition, as an exchange, an ATS could become a member of the Intermarket Trading System ("ITS"), a system that is currently limited to participation of traditional exchanges. ATS inclusion in the ITS would allow ATS participants to insert their quotations directly in the Composite Quotation System, providing greater transparency for all market participants.
On the other hand, as the Commission recognizes in the Release, certain negative consequences would ensue were ATSs to be considered exchanges without any further adjustments. As we discuss later, in such a case the Commission should use its exemptive power in several ways to create regulation appropriate in extent and substance for ATSs.
1. Continued Regulation of ATSs
as Broker-Dealers.
The Release suggests that ATSs could continue to be regulated as broker-dealers, with modifications to existing practices. As mentioned above, Bloomberg believes the overall result of changes in regulation could be positive, regardless of whether ATSs are regulated as broker-dealers or exchanges. The real question is what regulatory changes, specifically, does the Commission propose in either event? We consider below several specific issues.
Institutional orders. In the absence of a requirement to do so, a majority of non-market maker Tradebook participants voluntarily permit display of at least a portion of their orders in Nasdaq. This choice is generally made on a "default" basis for all orders using software provided by Tradebook, but the choice can be made or overridden on an order-by-order basis. Tradebook provides SelectNet access for all NASD members to all orders displayed in the Tradebook System, including some not displayed in the Nasdaq quotation.
Were it not the case that institutions display voluntarily, the Commission's legitimate concerns about market transparency could lead to requiring institutions to display. We believe, however, that requiring an ATS to include all participant orders in the public quotation may not be necessary since most of our participants already believe it is in their best interest to do so voluntarily. It appears to us that the trend towards voluntary display will continue, especially as more institutional traders become comfortable with the "Reserve" feature of the Tradebook System and its ability to mitigate the potential adverse impacts they may associate with displaying limit orders.
As the Commission knows, Bloomberg introduced the Reserve feature to the U.S. equity markets to create an incentive for traders to display more of their orders, and to do so more frequently. Others may have borrowed the term "reserve", but only Tradebook's Reserve incorporates the ease of use and flexibility that make voluntary display the rule rather than the exception in the Tradebook System.
We note one current regulatory disparity, however, which we believe is unfair to our market-maker participants and to the institutional investors they serve. While an institutional trader working an order in the Tradebook System may opt not to display the order in Nasdaq when he or she believes it is optimal not to display, a market-maker working that same order as an agent for an institution is denied the same option not to display the order in an ECN, even if the institution (as principal) requests that the order not be displayed. The result is inexplicably to favor institutions entering orders directly into an ECN, rather than through intermediaries. One could argue that the Tradebook System, and ATSs generally, would benefit from this disparity because it should encourage institutional investors to trade directly on the Tradebook System. Bloomberg, however, does not intend to discriminate against its customers or to disintermediate its market-maker customers. If institutions are to continue to have the option to avoid display (which we believe they should), we believe market-makers acting as their agents should have the same option. Bloomberg would like to provide a variety of trading options to its customers and then let them choose which strategy works best for them.
We further note that the option to display market-maker orders and, indeed, the obligation to seek Commission staff approval by no-action letter in order to be used by market-makers as a compliant ECN under the Order Execution Rules, does not extend to all ATSs, but rather only to those that engage in price discovery on a continuous basis. One could envision an ATS holding a series of discrete auctions occurring as frequently as, say, every one, two or five minutes in order to avoid the obligation to display that attaches to continuous-auction systems. Such an ATS could impose a cancellation penalty to reduce the risk that orders would be withdrawn, partially bridging the gaps between auctions and mimicking the features of a continuous auction. We urge the Commission to pay careful attention to this regulatory distinction in the future. We believe a substantial risk of unintended consequences exists in the seams, such as this one, between the regulatory zones. 9
Trade reporting. Whether or not the Commission requires ATSs to display all orders in their systems in the public quotation, we suggest that the Commission assign in full the requirement of reporting trades undertaken in an ATS to the ATS directly, as opposed to requiring the broker-dealer participants of an ATS to report. A complete assignment of this responsibility would eliminate the risk of duplicate reporting by an ATS and its participant broker-dealers and also would address concerns of institutional investor participants regarding anonymity 10 as well as relieving the concerns of broker-dealers about their own possible liability for non-compliance with the reporting requirements if the ATS fails to make the required report.
Non-participant access. The Commission asks in questions 15 through 17 of the Release whether an ATS should be required to allow non-participants to execute against orders in its system. The Commission has already imposed this requirement on ATSs that wish to remain in compliance with the Order Execution Rules, and it remains to be seen whether such a requirement will be problematic in a market break. Bloomberg believes that no regulation in addition to the Order Execution Rules is necessary because the forces of competition will cause ATSs to grant sufficient access to promote the Commission's objectives. We discuss below, however, the need to permit ATSs to screen all order entrants for financial ability to settle trades.
We believe that ATSs have an economic incentive to encourage order flow and provide liquidity. Over the long term, any ATS that does not provide appropriate access will be at a competitive disadvantage to ATSs that allow expanded access. Tradebook allows participants to display bids and offers and for each displayed bid or offer, to add an undisclosed quantity of shares as a reserve, and to execute orders against the bids and offers displayed in the system. Tradebook also allows non-participants access to the Tradebook System, but in a more limited sense: non-participants may execute only against orders on the Tradebook System; they cannot enter orders to be displayed to others. Non-participants may access Reserve quantities, which is not required under the Order Execution Rules since, unlike Display quantities, Reserve quantities are not "widely disseminated", but only up to a total of 10,000 shares per execution (displayed quantity plus accessed Reserve quantity). Participants may access Reserves up to the full amount on a single execution.
Fees. In question 16, the Commission asks how it should determine whether the fees charged by ATSs to non-participants are reasonable and do not have the effect of denying access to orders.
We believe Tradebook's non-participant access fees are appropriate in view of the current regulatory framework and commercial environment in which other ATSs charge access fees. We believe we should be allowed to charge non-participants for the services we provide them, including the communications infrastructure and the capital standing behind each trade. Since an ATS's capital risk increases as trade size increases, we think it is proper for ECN fees to take trade size into account.
We believe, however, the Commission should examine access fees closely. ATSs can choose whether or not to be "complying" ECNs, and therefore to accept non-participant orders. Broker-dealers operating under the requirement that they make reasonable efforts to obtain best execution of their customers' orders sometimes have to execute an order with an ECN when that ECN alone is displaying the best price.
In examining the current framework and weighing the competing interests, we understand the Commission's concern about fees and believe the Commission has the right, perhaps even the obligation, to examine the access-fee issue closely. We would be prepared to lower our access fees, in conjunction with other ECNs, in the interest of promoting greater market access.
Competitive SRO behavior. The Commission raises questions in the Release about increased surveillance of ATSs by their SRO if ATSs continue under the broker-dealer regulatory regime. In its evaluation of that issue, however, the Commission did not focus on its power under section 19(g)(2) of the Exchange Act to exempt an SRO, such as the NASD, from supervision of ATSs. Shifting regulatory oversight of ATSs from the NASD to the Commission, for example, would alleviate concerns about regulation of an ATS "broker-dealer" by a competitor.
In addition, the Commission could use section 19(g)(2) not only to exempt ATS "exchanges" from regulatory oversight responsibilities but also, if ATSs do not become registered as exchanges, to exempt NASD Regulation, Inc. ("NASD-R") from certain oversight responsibilities over ATSs. Unlike traditional broker-dealers, ATSs operate highly technical, computerized trading systems, an area in which NASD-R traditionally has little expertise. Tradebook, as a compliant ECN, has developed algorithms and procedures to comply with, among other regulations, the display requirements for widely disseminated orders under the Order Execution Rules and to avoid violations of NASD regulations prohibiting locked and crossed markets. In this respect, ATSs are more similar to exchanges, which are regulated by the Commission. That would of course shift the responsibility to the Commission and the Commission's Division of Market Regulation is already active in this area.
Since the advent of the Order Execution Rules, as discussed above, ATSs have faced increased competition from other ATSs and market centers, including Nasdaq. In addition, the required development of the order audit trail system ("OATS") by the Commission and Nasdaq will allow Nasdaq to monitor the ATSs markets closely and compile an extensive database of ATS market information.
Given the competitive implications of an SRO supervising and disciplining an ATS, the scope of surveillance activities of an SRO should not extend to the ability to view proprietary, nonpublic ATS system components and other competitively sensitive information, to examine trading algorithms or to receive notice of changes to an ATS's price development mechanism unless the inspection and the information derived therefrom is strictly limited to the regulatory arm of the SRO and not made available to the marketing division. Such inspection rights raise acutely the inherent competitive dilemma of requiring or permitting an SRO to supervise an entity that could potentially compete with it.
As a result, with respect to that specific aspect of ATS operation, the Commission might well consider exercising its authority under section 19(g)(2) of the Exchange Act to relieve the NASD and other SROs from the obligation to regulate ATSs and should impose its own direct regulation and surveillance over ATSs to the extent necessary to protect investors and the markets.
Alternatively, Bloomberg would also support the separation of NASD-R from NASD into an independent entity, an idea recently advanced by Commissioner Wallman. By definition, an independent NASD-R would separate surveillance activities from market functions and would benefit the market in general for several reasons. For example, it would alleviate the inherent conflict of interest presented by the NASD's regulating potential competitors.
Whichever approach is chosen, the Commission's regulation should apply consistently to all ECNs. The Commission's staff has advised Tradebook that if we were to introduce a "negotiation" feature identical to the one offered by a prominent competitor, it would qualify under the definition of "widely disseminated" in the ECN Alternative. The implication, of course, is that market makers' negotiated orders using such a tool would have to be displayed in the Nasdaq quotation, thus undermining the reason many participants have for using the tool. Yet, to the best of our knowledge, the Commission has not stopped our competitor from continuing to offer this feature without displaying the orders in the Nasdaq quotation. We understand that the Commission intends to act on such matters before issuing final no-action letters in connection with the ECN Alternative in January 1998. In the meantime, the negotiation feature is important for institutional customers working large orders. Lack of clear direction on this issue has impeded our ability to introduce a negotiation feature to satisfy our customers' demand.
Capacity and security of ATSs. The Release proposes implementation of guidelines for capacity and integrity of an ATS, including independent system reviews, contingency protocols and processes for preventing, detecting and controlling threats to an ATS system and reporting of system outages on a real-time basis. Capacity and integrity of ECNs are currently regulated via no-action letters which the ATSs have obtained from the Commission to assure their market maker customers that they are compliant ECNs within the meaning of the Order Execution Rules.
Bloomberg believes that this consultation is sufficient to address any short-term problems. Over the long term, as for-profit concerns, ATSs will respond to market forces; customer demand and an ATS's desire to supply its product in the face of competition will dictate expansion of capacity and strengthening of system integrity.
Financial integrity. We believe that the market applies sufficient controls on the financial condition of ATSs. The participants are sophisticated market professionals that are skilled and experienced at determining counterparty risk. Many of Tradebook's broker-dealer and institutional participants are willing to trade in the anonymous Tradebook market only if they have received certain guarantees of financial integrity of the system, most importantly the credit criteria that are imposed for access to other participants of the Tradebook System. B-Trade Services, the executing broker for the Tradebook System, applies objective financial criteria to base its acceptance of participants; to accept participants in any other manner would expose the Tradebook System to undue risk. To deny ATSs the power to screen market players for financial ability to pay would threaten the financial integrity of ATSs and undermine the participants' confidence in the ATS. Effectively, accepting all applicants, regardless of credit worthiness, would amount to a tax on ATSs that would be passed on to and borne by the credit-worthy participants who are the competitors of their unscreened counterparties.
Financial controls on access to an ATS as a participant are important and should not be eliminated through regulation. Competition among ATSs likely will provide protection against unfair denial of access. We believe it is in an ATS's self interest to grant access to as many participants as meet the ATS's credit-worthiness criteria. 11 Governmental regulation and imposition of a fair-access requirement on ATSs should be undertaken only upon a specific determination that such regulation is a better alternative to allowing commercial forces to govern.
One aspect of counterparty risk is the delay between the execution of a trade and the guarantee by the National Securities Clearing Corporation ("NSCC") of a trade, which currently becomes effective only at midnight of the day after the trade occurs. If the Commission is concerned about access and credit criteria in relation to ATSs, requiring the NSCC to become responsible for the trade in a shorter amount of time, ideally from the moment of execution of a trade, would reduce if not eliminate concerns about conditioning participation on financial criteria. If NSCC were required to guarantee trades, it would establish credit criteria of its own and the ATS would have not be involved in credit, and therefore access, determinations with respect to broker-dealer participants.
Proliferating SROs. We do not believe that it would be feasible or beneficial to the market for ATSs to establish a new, separate SRO. The Commission should not expect that ATSs would be able to regulate themselves effectively. ATSs are private, for-profit enterprises in a highly competitive marketplace. At a minimum, it is highly unlikely that the governing bodies of ATSs would be able to reach a collective agreement as to the purpose, rules and regulations of any such SRO. Even were they to reach initial agreement, since ATSs are for-profit, private enterprises, requiring the ATSs to work together in such a fashion might well diminish the competitive environment that today exists. As a result, Bloomberg does not believe a new ATS SRO would benefit it, the market or its participants and customers. 12
Anti-competitive practices. The Release asks whether the Commission should address anti-competitive practices of ATSs, if ATSs continue to be regulated as broker-dealers. We recommend that the Commission not take action at the moment, pending further experience. If an ATS in fact acts in an abusive manner, such as by turning away potential participants arbitrarily, other ATSs are available as alternative suppliers of the ATS service.
2. Proposed Regulation of ATSs
as Exchanges.
Definitional issues. The Release proposes that ATSs could be regulated as exchanges and deemed to fall under a proposed interpretation of "exchange" (question 32 of the Release) as an organization that both (a) consolidates orders of multiple parties and (b) provides a facility through which, or sets material conditions under which, participants entering such orders may agree to the terms of a trade. The Commission should distinguish, however, between a market center involving interaction among market participants and a dealer itself, which interacts with its own customers but does not facilitate interaction among customer orders. A number of broker-dealers have automated trade execution systems that involve only interactions between a broker-dealer and its individual customers, but not direct interaction between or among customers engaging in certain types of dealer activity. Unlike ATSs, these automated systems do not involve interaction among customers and should not be regulated as exchanges. 13
If ATSs, as private, for-profit entities, are to be considered exchanges, several adjustments and exemptions from current exchange regulation should be implemented:
(i) a for-profit ATS should not have enforcement powers or duties with respect to the business conduct of its participants, which are essentially its customers; 14
(ii) institutional participants should be exempted from the requirement, applicable generally to exchange members, that they register as broker-dealers or organize brokerage affiliates to act as the participants on the ATS "exchange";
(iii) limitations on members' (i.e., participants') trading under section 11(a) of the Exchange Act should be relieved; and
(iv) with respect to treatment of foreign securities, issuers should not be required to register under section 12 of the Exchange Act so long as the audience for an ATS is limited to institutional investors and broker-dealers, because these entities are allowed to purchase foreign securities in an initial sale under Rule 144A of the Exchange Act.
If an ATS were to be regulated as a non-exempted exchange, the Commission would be advised to use its exemptive authority under the Exchange Act to exempt it from numerous regulatory provisions that are not appropriate to impose upon for-profit, non-membership organizations. 15
Participants. The Exchange Act provides that all members of a national securities exchange must be registered broker-dealers. If the Commission's intention is to preserve the ability of ATSs to continue to deliver most of the services they currently provide, then ATSs regulated as exchanges should be allowed to have institutional investors as direct participants. The Commission would need, therefore, to exempt ATSs from this requirement if they were to register as exchanges and keep their institutional participants (unless the institutions organized as broker-dealers for the purpose of participating on one or more ATSs). At the same time, the Commission might wish to consider avoiding direct regulation of institutional investors, such as pension funds, banks, insurance companies and other entities that are regulated by governmental agencies other than the Commission.
Fair representation. Exchanges traditionally have been required to comply with fair representation requirements. Fair representation is a concern if exchanges are to operate self-regulatory machinery, such as inspections, discipline, arbitrations, and enforcement of the law. If, as we strongly recommend, the Commission refrains from imposing these responsibility on ATSs, it should not be necessary to dictate issues of an ATS's corporate governance or to require that participants have a voice in management of the ATS. In a competitive, market-driven environment, ATS participants can vote with their feet, and refuse to join, or depart from participation in, an ATS that behaves inappropriately. If the Commission were to implement restrictive regulation in this manner, ATSs would lose the ability to respond effectively to the demands and opportunities of the marketplace, thereby diminishing the incentives for participants to trade on an ATS.
Low-impact ATSs. If the "exchange" concept is adopted for ATSs, Bloomberg believes that low-impact ATSs and other similar markets should be regulated as exempted exchanges. Bloomberg believes that smaller market participants will have less of an impact on transparency of the market and therefore would not justify the increased cost of regulating such low-impact ATSs as non-exempt exchanges. Volume or market share measures should sufficiently define this type of exemption.
Access to market systems. Since ATSs are substantially distinct from traditional broker-dealers in their market activity and services, regardless of whether ATSs are deemed exchanges or are continued to be regulated as broker-dealers, we believe that ATSs should have access to and be allowed to become participants in market-wide plans currently subscribed to and operated by registered exchanges and the NASD, such as the Consolidated Quotation System, the Consolidated Tape Association and the Intermarket Trading System. Membership is currently available, for example, to the Cincinnati Stock Exchange, a totally electronic, quasi-ATS that is registered as an exchange and is operated out of Chicago, as well as to Nasdaq, which is neither registered as an exchange nor registered as a broker-dealer. These plans benefit the market as a whole by increasing transparency; by allowing ATSs membership in these plans, the market benefit in terms of liquidity and transparency would be increased significantly. We believe that membership in these plans should be available to other ATSs regardless of whether the Commission elects to register them as "exchanges" or to continue to register them as broker-dealers.
The benefits that the plans provide to the market as a whole apply equally to ATSs because ATSs operate interactive markets, different from the activities of traditional broker-dealers, that allow participants, including dealers, to interact directly with one another. Including ATS participant orders in the ITS composite quotation system would increase liquidity and transparency of individual ATS participant orders, individual ATSs and of the market as a whole.
Surveillance. Question 93 raises the issue of whether differences between automated and non-automated trading require materially different types or degrees of surveillance or enforcement procedures. We believe that automated trading by its nature provides less opportunity for fraud or manipulation to occur and a perfect audit trail if manipulation nevertheless is suspected. This feature of automated trading makes surveillance easier and minimizes the need for additional regulation.
Unregistered securities. If ATSs are required to be registered as exchanges, the Commission should not prevent trading in Rule 144A securities or other unlisted securities on an ATS, particularly if the only participants in the ATS are qualified institutional buyers within the meaning of Rule 144A under the Securities Act, since those buyers are allowed to be initial purchasers of the subject securities. We are not aware of any regulatory purpose served in denying them the opportunity to trade these securities in the secondary, transparent, publicized market in an ATS. We believe, therefore, that ATSs should be allowed to trade in these securities in order to promote transparency and liquidity and increase the efficiency of the secondary markets.
3. Regulation of Foreign Market Activities
in the United States.
The Commission has requested comments on whether investors would benefit from a clearer regulatory framework for entities that provide U.S. investors with the technological capability to trade directly on foreign markets from the United States. Certain institutional customers of Bloomberg believe that direct, inter-connected electronic access to foreign markets would provide them with equal access to these foreign markets and provide a more efficient manner to execute trades. The very distance of our U.S.-based institutional customers from these local markets creates a competitive cost disadvantage that electronic trading could erase.
Bloomberg believes that institutions should be allowed to have direct electronic access to foreign markets without necessitating U.S. registration of the foreign markets under the Exchange Act, which we expect would be a practical and political impossibility under current circumstances. 16 The access should not be conditioned on U.S. registration and regulation of the foreign market, so long as the investors are given clear disclosure of the characteristics of the foreign markets and the risks, including risks that arise from reduced governmental regulation and surveillance, or indeed none at all.
The Release also requests suggestions on regulatory approaches that would best address development of automated access to foreign markets. As the Commission is aware, the most common way to place foreign securities in the United States is through Rule 144A offerings. From Bloomberg's perspective, the Commission should not only permit but require transparent trading in secondary market Rule 144A securities by qualified institutional buyers ("QIBs").
These customers currently trade in foreign markets through U.S. broker-dealers and are aware that foreign markets are subject to different (and usually lesser) regulation than are domestic markets. U.S. investors, even "unsophisticated" retail investors, know the difference between the U.S. markets and foreign markets and need not be protected by the U.S. Government from the resulting risks. The Commission currently allows unsophisticated, retail investors to purchase country funds which are registered in the United States under the Investment Company Act of 1940. The prospectuses for such funds make elaborate disclosure of the risks, including the risks of trading in markets the Commission does not regulate. For example, in prospectuses of country funds investing in some emerging markets, it often is disclosed that war, political unrest and civil insurrection, governmental interference and governmental confiscation of the investment company's assets without compensation are all possible. Would it be inappropriate to allow a more wealthy and sophisticated class of investor, such as QIBs and even retail investors who, for example, meet the $5 million invested capital test for "qualified purchasers" in new section 3(c)(7) of the Investment Company Act of 1940, to trade directly, by electronic communications media, in foreign markets?
In regulating the granting of access to such markets, of course, the Commission should remain mindful of the differences between brokerage linkages and the provision of market information. Bloomberg and other news media, as the Commission knows, have constitutionally protected rights in the provision of financial news, whether by electronic or other means, that cannot be lawfully abridged by governmental prohibition or regulation, such as by requiring Bloomberg itself to register as a SIP in connection with its publication of market information. 17
If members of the Commission or of the staff believe we may be of further assistance in these matters, please let us know.
Very truly yours,
Bloomberg L.P.
By: /s/ Lou Eccleston
Lou Eccleston
By: /s/ Kevin M. Foley
Kevin M. Foley
cc: The Hon. Arthur Levitt, Chairman
The Hon. Isaac C. Hunt, Jr., Commissioner
The Hon. Norman S. Johnson, Commissioner
Dr. Richard R. Lindsey, Director,
Division of Market Regulation
Robert L. D. Colby, Esq., Deputy Director,
Division of Market Regulation
Howard Kramer, Esq., Associate Director,
Division of Market Regulation
Brian J. Lane, Esq., Director,
Division of Corporation Finance
Meredith B. Cross, Esq., Deputy Director,
Division of Corporation Finance
Paul M. Dudek, Esq., Chief,
Office of International Corporate Finance,
Division of Corporation Finance
-[1]- The Tradepoint Investment Exchange ("Tradepoint") is an electronic order-driven stock exchange in the United Kingdom. It is a Recognized Investment Exchange under the U.K. Financial Services Act of 1986 and a Regulated Market under the European Investment Services Directive. The London Clearing House acts as central counterparty on the exchange. Tradepoint provides instant and complete pre- and post-trade transparency and the ability for participants to trade equities free of any trading tariffs.
-[2]- Rules 11Ac1-1 and 11Ac1-4 under the Exchange Act.
-[3]- As the Commission knows, all ECNs are ATSs, but some ATSs, for example, the Arizona Stock Exchange, are not "complying" ECNs under the Order Execution Rules.
-[4]- Section (c)(5) of Rule 11Ac1-1 under the Exchange Act.
-[5]- The rapidly falling cost of dedicated communications bandwidth is a significant factor in making possible multiple inter-connections. Traditionally, the Commission has had to rely on a single market center, and then regulate it as a monopoly, because of the extravagant cost of maintaining duplicate communications facilities. That economic limitation no longer exists as a result of the reduction in bandwidth cost, and the monopoly-based regulatory assumptions will have to change as well.
-[6]- A possible survival measure would be for ECNs to skate beyond the boundary by eliminating a "continuous" auction, thereby escaping the reach of the Order Execution Rules. By instead offering short-term, periodic auctions, they could keep their participant orders out of the public quotation system. That escape route, which might well offer to ECNs their only realistic hope of remaining in business, would in fact subvert market transparency.
-[7]- Presumably, non-participants would be required to enter into certain standard industry agreements to provide for trade comparison and trade reporting, which would provide protections similar to those Nasdaq achieves under the ACT agreement.
-[8]- This solution is feasible because direct connections have become so inexpensive to provide. Alternatively, the Commission could solve the problem of the three-second delay by mandating that Nasdaq upgrade its technology dramatically. In a competitive market environment, however, the Commission could rely on market forces to solve the problem. In that way, Nasdaq would voluntarily improve its own technology and the Commission would achieve the same result with less regulation.
-[9]- See note 7, supra.
-[10]- Under the current regulatory regime, in a broker-to-broker trade, the seller reports. Where an institutional investor is the selling counterparty in a trade with a broker, the broker, as buyer, is required to report the trade; that requirement signals to the broker that the seller was an institutional investor rather than another broker. Some large institutional participants have expressed to us their concern, based on adverse experience, that even this information may help to reveal their identity in some cases. These institutions claim quite convincingly that, because of their size, their trading anonymity must be carefully guarded if they are to defend the interests of the millions of small investors they represent.
-[11]- Credit criteria, as discussed above, are integral to establishing and maintaining the confidence of ATS participants in an ATS and therefore to the success of an ATS and should not be considered prima facie unfair denials of access.
-[12]- History suggests that establishing and sustaining an SRO are not easily accomplished without a clear and compelling economic raison d'�tre . At various times through the years, as the Commission knows, there have been in existence approximately 100 regional stock exchanges (that is, exchanges not located in New York City), of which only some 35 remained in 1928. Securities & Exch. Comm'n, Report of Special Study of Securities Markets , H. Doc. No. 95, pt. 2, 88th Cong., 1st Sess. 928 (1963). On October 1, 1934, the effective date for the registration of exchanges under the Exchange Act, there were a total of 24 registered exchanges and 12 exempt exchanges and, by the time of the Commission's 1963 Special Study, the number had shrunk to 16 active exchanges, of which four were exempt exchanges. Id . at 911, 917. The number is smaller still today. To promote the organization of the NASD in 1938, the Congress permitted the NASD, in section 15A(e)(1) of the Exchange Act, to have rules preventing members from granting selling concessions to non-members in syndicated offerings, a powerful economic inducement for broker-dealers to join. To our knowledge, the last SRO to be formed under the Exchange Act (other than the Municipal Securities Rulemaking Board, which was created by congressional legislation and is limited to rulemaking) was in 1973, the Chicago Board Options Exchange; the other current exchanges, or their historical antecedents, were in existence at the time the Exchange Act was enacted.
-[13]- We believe the proposed interpretation of "exchange" would provide sufficient distinguishing features to exclude information vendors, bulletin boards and other entities whose activities are limited to provision of trading information were the interpretation of "exchange" to turn on order interaction between and among customers on a system that involves locked-in trades. Accordingly, we believe that new definitions do not appear to be needed.
-[14]- In a traditional exchange structure, members are subject to discipline by an exchange, but in return the members also participate in the development and implementation of the rules to which they are subject. Allowing participants in a for-profit ATS "exchange" to make rules concerning admission of participants, credit-worthiness, trading algorithms and similar matters would fundamentally change the structure of the ATS. Bloomberg believes such a result would be undesirable from a business point of view and should not be required. Assuming that the participants in an ATS would have no input in the rulemaking process or governance of the ATS, Bloomberg does not believe it would be fair to subject these participants to disciplinary action by the ATS "exchange".
-[15]- Sections of the Exchange Act which should be regarded as inapplicable to a for-profit, non-membership ATS include sections 6(b)(1) and 19(g)(enforcement of compliance by members with rules and laws); 6(b)(2) (any broker-dealer or natural person associated therewith may become a member); 6(b)(3) (fair representation); 6(b)(4) (equitable allocation of reasonable dues and other fees); 6(b)(5) (duty to have rules to prevent fraud and manipulative practices); 6(b)(6) and (7) (discipline of members and fair procedures); 6(c) (denial of membership to persons who are not broker-dealers or affiliated with broker-dealers and denial of membership); 6(d) (procedures for bringing disciplinary actions); 6(e) (ability to fix commissions charged by its members); 11(a) (prohibitions on members' trading for proprietary managed accounts); 19(b) (rule-making changes); 19(c) (ability of Commission to amend exchange's rules); 19(d) (imposition of disciplinary sanctions by exchange); 19(e) (review of disciplinary sanctions by exchange); 19(f) (review of denial of membership); and 19(g) (exchange enforcing compliance with rules by members).
-[16]- Eventually, it may be that a system of coordinate registration and regulation of exchanges throughout the developed world can be organized under the auspices of multi-national organizations such as the F�d�ration Internationale des Bourses de Valeurs and the International Organization of Securities Commissions.
-[17]- Indeed, the definition of SIP in section 3(a)(22)(A) of the Exchange Act specifically excludes "any bona fide newspaper, news magazine, or business or financial publication of regular or general circulation." Cf. Lowe v. Securities & Exch. Comm'n , 472 U.S. 181, 204 (1985), 1985 U.S. LEXIS 125: "Congress, plainly sensitive to First Amendment concerns, wanted to make clear that it did not seek to regulate the press through the licensing of nonpersonalized publishing activities." (Commission requirement that publisher of non-personalized investment advice in bona fide newsletter register as an investment adviser exceeded the Commission's statutory authority; unnecessary to decide constitutional question because Commission action exceeded statutory authority).


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Our phones probably carry more information about us than any other thing, but very often we forget to take precautions, lest we lose all of it. What is the precaution? A backup of all your data. You must be thinking, "Who has time to sit down and backup, I'll do it some other time." You and I both know, how much information we store on our phones, from pictures and songs to data, to-do lists, app data and so forth. Imagine, what would you do if you lost all that by some mistake? Heart-breaking, isn't it? As we say, "Prevention is better than cure", get to creating a backup of your data. For iPhones, creating a backup and restoring it is quite an easy task, with the help of iTunes. So, if you are thinking how to backup your iPhone on iTunes, take a look at the guides below.
Part 1: How to Backup an iPhone to iTunes
Creating a backup in iTunes is a simple task, all you need is your computer, your iPhone, a data cable, and iTunes installed. Also, make sure that you have the latest version of iTunes installed on your PC. In the coming lines, you will be seeing two methods on how to backup iPhone on iTunes, discussed step-by-step.
1)Backup with Data Cable
Step 1: Connect your iPhone to the computer. Launch iTunes. In the page that appears, click on the phone icon on the left side.
Step 2: Choose "Summary" from the sidebar. Choose "Back Up Now" under "Manually Backup and Restore". When you are finished, click "Done".
2) Backup with Wireless Sync
If you wish to use the Wireless Sync option to backup iPhone to iTunes, follow these steps.
Step 1: Turn off iCloud. On your iPhone, go to Settings > [Your Name] > iCloud > iCloud Backup and switch it off. Go to Settings > General > iTunes Wi-Fi Sync. Connect your iPhone to PC and sign in to iTunes using your Apple ID. Click on the phone icon.
Step 2: Select "Summary" and scroll down to "Options". Choose "Sync with iPhone over Wi-Fi" and click "Apply".
Step 3: Disconnect your iPhone from the PC. If your PC and iPhone are on the same Wi-Fi network, your phone will appear for wireless backups.
Thus, as you can see, by following these few steps from any of the two methods, you can easily backup iPhone 6 to iTunes (works for other iPhones as well).
Part 2: How to Restore an iPhone from iTunes
After the whole 'backup iPhone to iTunes' process is done, you can now easily restore all this data whenever you need it. Don't worry, you do not require any fancy software or application to do this, just your iPhone, your computer, and good old iTunes. To restore from iTunes backup, follow these few easy steps.
Step 1: Launch iTunes on the PC you used to backup your iPhone. Connect your iPhone to the computer. If a message appears for device password to "Trust this Computer", follow the steps provided on the screen. Choose your iPhone when it appears on iTunes.
Step 2: Choose "Restore Backup" in iTunes. See the size and date of each backup, and pick the most relevant one. Click "Restore". Wait for the process to be over, and enter your encrypted backup's password.
Step 3: After it restarts, keep your iPhone connected. Wait for sync to begin and you can disconnect after it finishes.
Tada! As you can see, by following these few simple steps, you can easily restore from iTunes backup in no time!
Part 3: The Best Tool to Backup & Restore iPhone You Should Know
You may be wondering how to backup iPhone without iTunes. Don't worry, dr.fone is your answer! Compatible with all versions of iOS, including iOS 11, iSkysoft is the one-stop solution for data management and restoring for iPhones, without any kind of hassle. You may not want to follow so many steps to take the help of iTunes to back up your iPhone, so don't worry, leave it all on iSkysoft. Let's take a look at some of its main features:
- You can read, preview, select, and restore the data you have backed up in iSkysoft. All the data is under your control!
- Supported file types that you can restore include contacts, photos, messages, music, video, media files, WhatsApp chats, call history and lots more.
- Backup and restore your iPhone with just one click! Whenever you need the data, they are easily available for restoring from iSkysoft!
- You can also save any wanted data as printable files! That's not possible with iTunes.
Now, let's take a look at the steps
Step 1: Connect iPhone to PC. Run iSkysoft and choose "Data Backup and Restore." (You can download the software from the "Free Download" buttons belows.
Step 2: Choose the files you want to backup. Then, select "Backup".
Step 3: Wait for the whole process to finish, which usually takes a few minutes. After the backup process is done, you can also check the content of all the backup files. To restore data, click on the options "Restore to Device" and "Export to Mac", which will allow you to restore all the data that you want, from your computer to your iPhone.
Thus, as you can see, the dr.fone is a great alternative if you do not want to go through the process of backing up and restoring your iPhone through iTunes. This also works as a great solution, if iTunes stops to work on your computer for some reason. All you need to do is download dr.fone on your computer and you are good to go!
Sitting down to backup data is a boring task, I know. But it is more important to take this step to save all your precious data, just in case you may lose it, isn't it so? In this day and age, we have shiploads of information as well as data on our phones and regaining them all back is not an easy task. You can avoid that by simply making a backup of everything, by following the guides here!

subset: commoncrawl


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There's seems to be something about polar bears that really sets off the climate change fact-checkers. Mention that the situation for the bears is not quite as dire as we were told they would be 15 years ago and they can't wait to sink their teeth in.
In early September this year, an Australian a woman I've never heard of gave a lecture to students at her former girl's school and in the process made some critical remarks about Al Gore's 'An Inconvenient Truth'. Gina Rinehart said, among other things:
"I'd heard that senior school students in a previous headmistress's time, were having to watch … An Inconvenient Truth. Catchy title, but sadly short on delivery as far as truth is concerned, e.g. the sad loss of polar bears, when actually their numbers have increased…"
The folks who 'fact-check' at the Australian Broadcasting Corporation (ABC) seemed to feel that Ms. Rinehart needed to be taken down a peg for the temerity of that remark, perhaps as it afforded an opportunity to take me down along with her: it seems some things I've said or published over the last few years were identified by her office as the source of her remark that polar bear numbers had increased.
In a long-winded essay of more than 2,500 words published yesterday (26 October 2021) the fact checkers provide one of the best examples yet of how convoluted is the official answer to the question: have overall polar bear numbers declined or increased over time? They interviewed a number of experts from the Polar Bear Specialist Group (PBSG) who had a lot to say but claimed it is impossible to address the global population issue.
Sadly, the question of how many polar bears exist today compared to decades ago is unnecessarily complicated and messy, as I discovered years ago. I dealt with this topic in my latest book, The Polar Bear Catastrophe That Never Happened, so for now I'll just quote a bit from one of the chapters and let you decide for yourselves if the experts quoted by the ABC fact-checkers have a strong enough case to say without question that Rinehart was wrong. For example, you might ask why the PBSG experts used the estimate generated for the Kara Sea subpopulation of about 3,000 bears compiled by Russian researchers (Matishov et al. 2014) for their official IUCN 2015 assessment (Wiig et al. 2015; Regehr et al. 2016) but didn't include that number in this 'fact-check document – or why they similarly used an estimate of 2,000 for East Greenland for the 2015 assessment but provide no number for this 'fact-check'. I'll probably have more to say later.Continue reading


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Of late gray hair has gone from feared to preferred as models, celebs, and young women across the world head to salons for the silver-y tone request. During the last two years, a large number of celebrities have stepped out with gray locks. Even Pink shade has gone gray. One of the renowned colorists in New York City claims that though it is not conventional, yet it goes well very nicely on a few skin shades.
According to hairdressers, during the last few years, the number of young women who've requested gray dying has shot up abruptly. For some costumes gray hair is an essential addition. If you like to turn your black hair into gray at your young age, consult any of the renowned colorists.
But, the problem with the men and women presently suffering from the problem of graying.
What must you "Do's" to prevent graying hair
Going gray in young age is a matter of concern, though for the aged it is normal. But, it doesn't mean that you can't fight against it. There are several natural ways that you can " do" to stop growing gray hair. Or you can reverse the growing gray.
1. You must try to cure some of the medical conditions like thyroid disorders and stomach or intestinal disorder, or presence of any bacteria or parasites in the body.
2. Take the maximum amount of vitamins and minerals. Start growing wheat grass that is much helpful for supplying nutrients to your hair to prevent it from being gray. So start growing wheat grass to stop growing gray hair. It shows dramatic improvement.
3. Consume para amino benzoic acid more and more. It is found in dairy products, eggs, molasses and whole grains. It promotes hair growth and also prevents graying hair. Also, it stops hair coming out gray.
4. The climate where you live has a great impact on your scalp and the hair. Proper blood circulation, protects hair from being gray. You should help blood circulation to transport to your hair follicles to prevent gray hair.
5. Stress plays an important role not only in overall health, but also in the skin and scalp. Get rid of stress and strain. It will help prevent graying of hair.
Related:- Does stress cause gray hair?
What are the "Don'ts" that you must avoid to prevent gray hair
Hair starts graying with age when the cell that naturally produces pigment starts losing strength. Graying of hair is largely because of growing older. But this is not always the reason for graying hair. Also, there are other factors that can cause graying hair.
Among them, malnutrition, stress, genetics, or health disorders, and some lifestyle disorder subscribe to gray hair problem. Avoid a few things from your life if you want to delay graying of hair.
1. Quit Smoking. The more you smoke the more you call in danger for your hair. Smoking is one of the worst lifestyle disorders. Smoking expedites the aging process of the whole body. So, the first thing that you should promise today, even at this moment to stop smoking forever.
2. Say good bye to alcohol. It is very harmful for your skin and hair. It causes premature aging and makes the appearance older than the normal age. The person lost interests in work without puffing smoke. The smokers derive false pride out of puffing of smoke only to get energized at work. But, shun the habit of smoking now.
3. Give up coffee and junk food. Also minimize the consumption of refined sugar and flour. These food items only reduce your energy levels. You will get nothing in return out of them.
4. Your body will get nothing return them. To stay young your body needs nutrients, but junk food or coffee eats up the nutrients.
5. Never be under stress and anxiety. Prolonged periods of tensions and anxiety or other similar psychological conditions can lead to a gradual or sudden appearance of gray hair.
6. Never get disturbed sleep. Take care that you got sound sleep last night. Enough rest keeps you stress free all the next day. If your body and mind open up with full vigor, it won't have a devastating effect on your skin and hair. So take care that you are not awake late at night to waste the hour allotted for sleeping.
7. What you eat, what you get. Never indulge in wrong eating habits only to satiate your taste buds. Consider their effects on your hair. Consume food rich in copper, iodine, selenium etc.
Must Read:-
- Top 9 Vitamin and Mineral Rich Foods For Stopping White Hair From Spreading
- 20 Foods Highly Loaded With Vitamin B12 (Divided By Types)
There you have got some "Do's and Don't s" that will help prevent your hair from graying. And also, the hair-health will get amazingly better day by day. If there are any other helpful tips, you can come with them to share with us and to all.


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Kitagawa Utamaro (喜多川歌麿) (artist ca 1753 – 1806)
7 Imaginary Chinese Creatures (shōjō) in a Drunken State (Shichi-nin shōjō zuburoku no zu - 七人猩々酩酊之図) - left panel of a triptych
ca 1795
9.75 in x 14 in (Overall dimensions) Japanese woodblock print
Signed: Utamaro suichū (in a drunken state) hitsu
Publisher: Tsuruya Kiemon
Museum of Fine Arts, Boston - the full triptych The British Museum translates the title of this triptych as Picture of Seven Drunken Sake Sprites. This subject may also be a parody of the Seven Sages of the Bamboo Grove (Chikurin no shichi-kenjin).
This composition is one of the most unusual and rarest among all of the works of Utamaro, an artist who some scholars believe is the greatest master of ukiyo-e of all time. The questions surrounding its origins are fascinating. Whose idea was it to produce such a piece? Is there a hidden message or symbolism we are unaware of? Its charm is obvious, but what lies below the surface? These are questions which may never be answered, but speculation is half the game, isn't it?
The shōjō (猩猩) has its origins in Chinese folklore. It is often described as being half man, half ape. That makes sense when one parses the meaning of the kanji characters: orangutan or sot. This gentle creature with long red hair is harmless and good natured, but has a particular liking for saké. The long, unruly red hair may draw a direct connection to orangutan. What is a bit puzzling is that there is an oft repeated belief that the hair of the shōjō could be used for an especially rare and valued red dye.
Robert Hans van Gulik in his The Gibbon in China: An Essay in Chinese Animal Lore traces on page 27 the origin of this creature, the xing-xing in China, back to the 2nd century. "In Japan the hsing-hsing... was promoted to a Wine Spirit, represented as a mythical animal with a fox-like face and very long, red hair, always drunk and dancing merrily. This shōjō motif frequently appears in Japanese applied art, and the great poet and art-critic SEAMI (世阿弥 1363-1443) devoted a Nō-play to it: there the shōjō, dressed in a magnificent brocade robe, executes a complicated dance around a huge wine-jar of green porcelain."
Van Gulik adds that it was reported that "wester barbarians" ate the meat of the xing-xing and used their blood as a dye.
Another source is Japanese Art Motives by Maude Rex Allen who notes on pages 50-51 that shōjō were said to live by or in the sea and come on shore to revel. Fishermen were said to lure them by placing large containers of saké near the water. Allen quotes a Japanese saying: As drunk as a shōjō as a warning to young people against overindulging in intoxicants. This differs little from Nancy Reagan's "Just say no to drugs!"
Allen notes on page 83 that a particular type of dragonfly, a bright red one, is named a shojo-tombo after the color of the hair of these mythical creatures.
Before we leave the topic of shōjō altogether we thought we would mention an unusual print by Sadafusa in the Museum of Fine Arts in Boston: The Buddha of Sake Drinking (Sakenomi Nyorai). In it a shōjō is used as a stand-in for a buddha in an almost traditional presentation. The elaborately robed shōjō stands barefoot on a flowering lotus pod. In his right hand he holds a bottle of saké and with his left he holds a saké bowl behind his head as if it were a halo.
In 1796 the government issued a ruling that the names of beautiful women were not to appear on prints unless they were famous courtesans of the Yoshiwara or prominent geisha. Perhaps this print lacks the names for this reason or perhaps it was because the women chosen were meant to be more symbolic considering the scene.
1) In color in a three page fold out in Ukiyo-e Masterpieces in European Collections 10: Museo d'Arte Genoa, I, supervised by Muneshige Narazaki, 1988, #151. They date theirs from 1789-1801.
2) There is the full triptych from the Vever Collection illustrated in color in Gimē Tōyō Bijutsukan, Pari Kokuritsu Toshokan (Musée Guimet, Bibliothèque Nationale, Paris, Henri Vever Collection, Huguette Berès Collection), editor Yamaguchi Keizaburō, 1980, pp. 180-181.
beautiful women (bijin-ga - 美人画) (genre)
Tsuruya Kiemon (鶴屋喜右衛門) (publisher)
Yūrei-zu (幽霊図 - ghosts demons monsters and spirits) (genre)


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By Edward Nawotka, Editor-in-Chief
Today marks the three year anniversary of the failed Green Revolution in Iran, an occasion we mark by pointing to the global success of Zahra's Paradise, a wildly popular graphic novel about a protester who disappears. Over the year's we've looked at several stories that discuss the various ways in which publishers have become politically active, including
- Iranian publisher Arash Hejazi–also the doctor who treated slain Iranian protestor Neda Agha-Soltan–discussing Iranian censorship
- A look at Venezuelan president Hugo Chavez's "Color Coded Revolutionary Reading Plan
- Nigerian president Goodluck Jonathan's Facebook-based reading campaign.
- A report from Tahrir Square from a Bloomsbury Qatar editor…and much more
Very often, politics and publishing can't help but mix. At some imprints, it's even entire point, as discussed in our feature about the UK's Telegram Books, "Publishing as Politics, Publishing with Purpose." Of course, this also raises the question of where a publisher should also draw the line.
Pamphleteering, propaganda and agit-prop have long been a part of the publishing process. It's here to stay. So long as publishers stick to their ideals — whatever they may be — and are true to their audience, we can live with that. But as soon as the feeling creeps in that the publishers are being bought-and-paid for to become part of a larger political machine, it becomes far more troubling. All all too often it seems publishers are creeping closer and closer to that line.
So tell us, what do you thing: what role should publishers play in political activism?


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It's Like Open Mic Only Different
Here's how it works.
It's like any rambling conversation. Don't try to read it all. Jump in whenever you get here. Just go to the end and start talking. EVERYONE is WELCOME.
The rules are simple — be nice.
There are always first timers and new things to talk about. It's sort of half "Cheers" part "Friends" and part video game. You don't know how much fun it is until you try it.
Social Networking Taking Too Much Time?
Are you spending lots of time social networking, but starting to wonder whether it's worth the time you're investing? Do you have lots of friends, but don't seem to be getting closer to where you want to be going? We're going to explore other ways to share what you're up to.
Tonight it's about creative networking:
- how to get the most out of Twitter conversation
- how an eBook might help build your reputation
- the idea of ezines and manifestoes
- guest posts and writing projects
- other ways to get your ideas out there
ahem . . .
And, whatever else comes up, including THE EVER POPULAR, Basil the code-writing donkey . . . and flamenco dancing (because we always get off topic, anyway.)
Oh, and bring example links to share.
–ME "Liz" Strauss
image: sxc.hu
Related article
What is Tuesday Open Comment Night?


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What's on the horizon for luxury real estate in 2024?Find out now
Charming 3 bedroom with over 1200 square feet of living space. This home is situated on a treed lot in the heart of Midland. The kitchen includes all appliances and a large eating area and adjoins. This home has a formal living room with hardwood flooring, large picture window plus a family room. There are 1.5 baths and a nice size laundry room. 1 car attached garage, plenty of parking and a private backyard. A new roof is scheduled to be installed in July!
Listing courtesy of


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Investment Calculator – Should You Sell Before New Capital Gains Rate Increases Occur?
One of the differences between the presidential candidates is their tax policies. Current tax rates arise from two pieces of legislation supported by and signed into law by President Bush during his first term.
One of the differences between the presidential candidates is their tax policies. Current tax rates arise from two pieces of legislation supported by and signed into law by President Bush during his first term, as follows:
1. The Economic Growth and Tax Relief Reconciliation Act of 2001 lowered ordinary income tax rates for individuals.
2. The Jobs and Growth Tax Relief Reconciliation Act of 2003 reduced tax rates for long-term capital gains to 5% and 15%.
Both of these tax cuts are scheduled to expire on December 31, 2010 if not extended or made permanent. Regardless of the presidential election result, a Democratic majority in both houses of Congress is likely. Senator Obama will not likely wait until the tax cuts expire in 2010, and is expected to propose immediately raising capital gains tax rates to the 28% that existed during President Clinton's administration. In contrast, Senator McCain supports making the Bush tax cuts permanent, leaving capital gains rates at 15%.
Normally, a taxpayer is motivated to delay taxes, since taxes reduce the amount available to invest. This is the rationale for investing in 401(k) and similar tax-deferred plans. For example, assume you have $100 of built-in gain in your portfolio. If you sell now and pay capital gain tax of $15 (15% of $100), you have only $85 of gain to reinvest on a going-forward basis. Conversely, if you hold, you pay no capital gain tax now and the entire $100 of built-in gain continues to earn a return for you. Over time, this difference becomes magnified if one is fortunate to obtain higher investment rates of return.
However, if tax rates are going to increase, taxpayers are potentially motivated to do just the opposite, thereby incurring an accelerated but smaller tax. Stated otherwise, an investor with built-in gains in the portfolio may be motivated to sell winners before the tax increase. Even though this results in less money being available, the investment results may not pay for the higher taxes that are subsequently due.
If an Obama victory occurs, this raises the question of whether a taxpayer with accumulated capital gains should purposefully accelerate the capital gains in order to pay taxes at the lower current rates that currently exist. A similar question occurs with a McCain victory, although probably a year later.
With these two offsetting and contradictory forces at play, a sound decision requires calculations which consider the change in tax rates and the time period that one could otherwise forestall the tax obligation. To assist with what might otherwise be complicated calculations, the following interactive tool assists in answering:
1. What is the difference in gains in my investments if I hold (i.e., do not sell before the expiration of the Bush tax cuts), as opposed to selling and reinvesting my after-tax gains?
2. If I hold because I want more of my gains working for me (see question 1 above), how long would it take for the additional growth in my built-in gains to offset the cost of being subject to higher future capital gain rates?
3. Given my investment time horizon, should I sell now (i.e., before a tax rate change) and reinvest the remaining gains, or hold until my investment time horizon ends? What is the benefit or lost benefit of selling now?
The answer to these questions depends on two variables, each of which can input into the calculator:
1. Future capital gain rates - The higher the future capital gain rates, the longer you must hold your investment to come out ahead.
2. Future rate of investment returns - The lower the future rate of return on your investment, the longer you must hold your investment to make up for the higher taxes.
One can also address the question by starting with your expected holding period. The following graphic allows you to input the expected holding period of the investment, and see whether one should sell now (a positive number will be shown) or continue holding (in which case a negative amount from the sale is shown).
By Fulcrum InquiryABOUT THE AUTHOR: David Nolte
Expert Website: https://www.fulcrum.com
Call (213) 787-4100
Expert Website: https://www.fulcrum.com
Call (213) 787-4100
Mr. Nolte has 30 years experience in financial and economic consulting. He has served as an expert witness in over 100 trials. He has also regularly served as an arbitrator. Mr. Nolte has achieved the following credentials, CPA, MBA, CMA and ASA.
Copyright Fulcrum Inquiry
Disclaimer: While every effort has been made to ensure the accuracy of this publication, it is not intended to provide legal advice as individual situations will differ and should be discussed with an expert and/or lawyer.For specific technical or legal advice on the information provided and related topics, please contact the author.


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It has been wonderful to see the Duke and Duchess of Cambridge with their beautiful new-born son this week.
Our surgeon Asim Shahmalak was one of millions of people to welcome the new arrival on Twitter.
It was hilarious to see Prince William joking about his hair loss when he showed off the new baby to the world.
Asked about the new baby's hair, thinning William joked: "He's got way more than me, thank god."
You can read Prince William's remarks here:
This isn't the first that the royals have joked about William's fast receding hairline.
Two years ago, Prince Charles joked about William's 'thinning hair' at William and Kate's wedding reception.
And Prince Harry has also had some fun at his brother's expense.
When a portrait of the two brothers was unveiled three years ago, Harry joked: "William has got given more hair."
The remarks show how lucky we are to have a royal family who are such fun.
We would be more than happy to help Prince William with a hair transplant at the Crown Clinic.
But we imagine that the royal is going to be far too busy with baby duties for a long time to come.


text: GETTING ORGANIZED...or one can at least hope! June 11, 2008 travelbug1237 Comments (29) Not rated yet HH ME'ers!!!, (Hello Hello, Machine Embroiderers)Just back from a glorious trip to the beach. Yeah!!!! While there, I came to the conclusion that before I take another embroidery class in order to blog about it,I needed to …… Whoa! …… Stop!......... & GET ORGANIZED!!! I needed to:1. WRITE DOWN what I already have. 2. FIND A PLACE to put it.3. ASK for your input.4. INVITE you to 'share my beach home" (see photo) for a visit (1-1 tutoring on machine embroidery, the Brother PE-700 machine itself, computers, or…… ???? ( LMT's….(licensed massage therapists are you there??? )5. Purchase items ( shop – yeah ) if necessary to help me get organized for my new passion.6. GET HELP with what I'm not getting done myself or getting frustrated over.The solution looked simple on paper, ……but it would involve more time, $ and energy. So I then realized I needed to regroup, analyze the situation, & then ….. ta dah….PRIORITIZE….!!!!1st thing done - MOVE the guest BED OUT of the guest room/office to make more room.!!!! (There's still room for more gadgets !!! & I would LOVE your input on that topic in the forum.2nd- went shopping…this time with a specific plan & purpose, but forgot the measurements ..oops) New Furniture I bought a special craft table that 'hides doodads galore', a folding cutting table and a SIMPLE sewing table for my Brother PE-700 that would hold a few important items. I also got to find a place for my DARLING unexpected Orlando furniture purchase (see photo). It's 1 of a kind & it always makes me smile.! Junior Senior? Aarrgh….I also bit the bullet and bought a laptop PC so I can eventually do machine embroidery like most everyone out there does. (……..by downloading the designs over the internet!!!!). Personally I DON'T like the little cards that can get lost. That's me, but that's how I feel at least for now. Speaking of losing things…(I wear my reading glasses on my head, have my keys around my neck on a lanyard and I've switched to a fanny pack for Pete Sakes…just so I can get home with what I started out with!) I am just a JUNIOR 'Senior Citizen'…I am not even a 'full fledged discount on my meals' senior yet…and lo & behold I have had to resort to drastic measures already. What happens when I get REALLY old ????!!!! Please fill me in!!! Organizing Designs OK back to computers….not my favorite subject,….. I know there was one fellow at Community Circle who took time to try & explain how it (downloading) could be done with modifications to my new Apple, but the reality is…the Apple store here isn't geared for that and I am a duck out of water for the time being with everything else I'm trying to learn. So, my ME teacher helped me order a laptop for downloading all those BEAUTIFUL designs out there!!! But it is going to be VERY important that I 'organize them' into something…& thank goodness I had purchased the Catalog Xpress & Alphabet Express in Orlando. (So that 'cart before the horse' purchase turned out ok!!!) Calling All Newbies! I have yet to down load 1 thing. Sigh…I am SUCH a beginner…but that's OK. It's where I am for now. I read of course, the 'advanced' bloggers and admire them & all those who really know their stuff…and my goodness, so many of the readers have so much experience too!!! What a wealth of information and experience there is on AnntheGran. Once in awhile I read something from someone NEW like myself. The website is for ALL ME'ers!!!! No question is TOO basic!!! The advanced people are SO willing to help us Newbies. Now remember folks, my blog is specifically written to make sure beginners like me, can learn from others, enjoy OUR journey starting out & maybe avoid some mistakes. Software Experiences? I 'd LOVE to hear from those of you who have either of those 2 products (Catalog & Alphabet Express - product reviews here)….How has it worked for you? How DOES it even work???? TIPS PLEASE etc etc or better yet…show me at the beach!!! (If I had a wiggling carrot icon that I could put in about now I would! Just picture a cute seagull dangling that carrot swaying in the ocean breeze!!!)I can't wait to start on Ann's lace hearts because I NOW know how to make lace!!! Yeah!!!!! Speaking of which….HOW MANY OF YOU TRIED LACE for the 1st time??? Is there even ONE of you out there who did???? I haven't heard from you!!!!!!…..Some said they were going to try….Did you???? Hmm?I also bought a new phone and a new 'head set' so that my hands can be totally free when I am getting instructions over the phone.( eventually) (It isn't set up yet..but soon I hope.) Feel free to send me your phone numbers in the meantime though!!! (Did I mention that I am spending ALL of my retirement checks for the moment!!!! ) Two Simple Questions Now as always, I have a gazillion questions but will narrow them down to 2….Don't Faint!!! 1. Please share your MUST HAVE gadgets or items you wouldn't want to live without). ( w/price and why you love them so much - if you have the extra time for details) So far at the forum we have a short but great list & it is really helping me prioritize. (Thread Pilot, Havel scissors, the tote from Ann's store, tweezers, magnifying glass, & paint brush). You can give me your ideas by clicking here. 2. Space Design ideas….When you SIT DOWN to machine embroider….WHAT do you REALLY need and WHERE do you put it?????? Judy in Florida shared a picture of a wall unit that I'd LOVE to incorporate!!!!!! You can answer that one by clicking here.So, thanks ME'rs who have already contributed to the 'gadgets forum & have supported me along my way here as a NEWBIE! I love your thoughts- be they long or short. I really do love them!!!Have a great June everyone!!!….I hope you'll send us photos & give me hints & ideas etc….!!!! Hugs,Cathy in Oregon….who just shared her rose garden with a deer this morning. P.S. (I'm sending this in a bit early because I have a grad class for a week coming up fairly soon and it will be time intensive.) I'll still check on my blog and the forums. HAPPY EMBROIDERING!!!! Not rated yet. Please Log In or Register to Rate Tags: catalog xpress , alphabet xpress , brother pe700 , thread , lace , tote bags


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There are many smart security cameras on the market. Nest is a popular brand offering cameras at $199 and $299. Netgear, another popular brand, offers the Arlo camera at $199, while Amazon offers the Cloud Cam for $119. Nest requires a subscription-based cloud service to store video in the cloud so that you can view it from anywhere. The Nest Aware cloud history service is $100 a year for 10 days of history and goes up to $300 a year for 30 days of history. It's bundled with other services as well. When reviewing home technology, I often prefer to start at the bottom from a cost perspective and see if the features provided are sufficient before I move on to technology with a higher price tag. This month I'm reviewing the Wyze Cam, which sells for $19.99 at Wyzecam.com. No, that is not a typo; the camera costs 20 bucks and does not require a storage subscription. Interested? Keep reading.
When the Wyze Cam camera arrived in the mail, I was shocked at how small the box was: literally a 2-inch cube. Do good things come in small packages? My wife Bibi's reaction was, "Wow, this camera is cute." The camera comes with a flexible stand, which allows it to be raised, tilted and swiveled to point in any direction. It also comes with a magnetic base and an adhesive for wall mounting (although I did not mount mine). The camera requires a nearby power outlet (it is not battery powered) and of course a Wi-Fi connection.
Once plugged in, a simple application of the camera is as a baby monitor that will allow you to view your little ones from anywhere. I recommended this to a colleague who is a new father and he loves it. There is also a two-way voice connection that allows you to speak to the camera and hear sounds along with viewing live images.
Right out of the box the camera offers both sound and motion-detection options. When movement or sound is detected, the camera records and uploads to the cloud 12-second clips, which are saved for 14 days without a subscription. That is a huge advantage over some other services that charge hefty fees for a similar feature.
I found the motion sensor to be accurate, detecting primarily actual movement. Occasionally, I received empty motion clips that seems to be triggered by cloud movements and shadows. There is a sensitivity option that I dialed down to address this. The sound clips did not seem very helpful in my experience, though I did discover that houses make sounds—be it the air conditioning or heating or the refrigerator compressor switching on. I dialed down the sound sensor drastically, hoping it would still capture a glass breakage or other loud sound but not bother with the rest.
There is a separate smoke and carbon monoxide alarm sensor that will notify you if any of your external house alarms are triggered, which can be very helpful in a real emergency. The camera also has wide angle (110 degree) viewing capabilities. When I placed it in my foyer I was able to monitor both my front and side doors simultaneously since they are set at a 90-degree angle of each other. If you require coverage of angles wider than 110 degrees you can use two cameras and daisy chain from one power source to multiple cameras, avoiding extra wires.
There is also a night vision mode that I set to Auto; it produces high-quality videos even with all the lights in the house switched off.
The camera is only for indoor use, so I placed it on a windowsill facing the street to capture activity outside my front door. It worked well during the daytime, capturing all movements to my front door. The camera is compatible with the Alexa, so I can ask to view a live image of my front door from a compatible Alexa-enabled device (Echo Show). The wide angle and motion detection works against you in this scenario as the motion sensor picks up each car traveling on your block. Fortunately, a recent update to the software allows you to set a specific zone for motion detection. I set it to the narrow view of my front path while excluding any movement beyond the curb. This defines the motion-detection zone, but once motion is detected in that zone the full camera view is recorded. Nighttime video, however, was a little bit of a disappointment on my window due to the reflection of the glass. Perhaps if you have a better lighting in front of your house it will give you a better image. In a recent interview with the Wyze Cam CEO, there was a hint of an outdoor version of the camera in the company's near future. I will hold off on purchasing outdoor cameras for a while until this is released.
Motion detection on Shabbat poses the big challenge for this camera as well as other smart cameras and smart home devices. When speaking with halachic authorities, the common opinion is that triggering motion detection that is not for your benefit is not a problem. However, where the trigger is for your benefit it can be problematic. For example, if your neighbor's motion light sensors are triggered when you pass on your way home, this may not be an issue since the motion detection is for your neighbor's benefit and not yours. However, setting up a motion-sensitive camera in your own home is clearly for your benefit and this may not be permissible if it will trigger events on Shabbat. In a previous article I quoted rabbinic authorities who believe keeping an Amazon Echo listening in your home on Shabbat is problematic for similar reasons (see Alexa get Ready For Shabbat ).
The app does allow for turning off the motion detection at certain times during the day but does not allow you to choose the day of the week, or to choose times based on sunset for Shabbat. Plugging the camera into a smart switch that turns the entire camera off for Shabbat is a solution (one that I previously recommended for the Amazon Echo itself). I did this for a while and it rebooted after Shabbat without issue. However, I wanted to find a way to keep the safety of the recording going 24/7 but to just turn off the motion-detection triggers over Shabbat and Yom Tov. I have found a solution and it is a solution that may work for other smart device integrations. It is a bit elaborate, so check back soon for Part II…


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Dear Students and Parents,
We are writing this letter at the request of the Center for International Programs to provide you with the clearest information and thinking we have about Study Abroad for students who have psychiatric disorders or psychological difficulties. Our three major concerns are that students maintain their treatment plans while abroad, inform important personnel of their disorders/concerns, and take good care of their medication needs.
First, it is critical that students stay with their prescribed treatment plan to make study abroad a success. Our experience is that students who do not follow through (especially with medication) end up having a much more difficult experience, causing the host family and program directors serious worry, and/or having to return to the U.S. before the end of the program. The best way to avoid these difficult outcomes is to follow the plan that you've made with your providers and to be in touch with them or with providers in the host country if you notice any concerning symptoms or have any very disruptive experiences.
Second, it is in the best interest of students who have been diagnosed with psychiatric disorders or who know they suffer from psychological difficulties to fill out the Health History form accurately and to let the program manager at K and the program director at the site know of their situation as early as possible. Some students are hesitant to provide this information. Over the years, we have found that clear communication makes a significant difference in students' experiences because a safety network can be developed. That network seems to reassure both students and parents and puts all of us in the best possible position if there is a major problem.
Some students are not forthcoming about their history with mental health because they believe that Study Abroad will provide a respite from their problems. In our experience, that is not usually the case. There are so many challenges in living in a different country and some of those challenges create considerable stress. We have found that the challenges of a new environment can easily exacerbate psychological concerns and psychiatric symptoms.
The third important concern is medication. It is very helpful to take all the medication that you'll need with you, along with a letter from the prescribing provider indicating why you are taking the medication. If for some reason that cannot happen, it is important that you make a connection with a prescribing provider early in your stay abroad. We have found that even medications with the same name may be slightly different because they are manufactured abroad. We also know that it is often difficult to get an appointment at the last minute and running out of medication can complicate life a great deal.
Students often wonder about discussing their mental health situation with their host parents. Typically, a pretty matter of fact statement early on can be helpful (e.g., "I take medication because I have experienced depression. I don't think you need to worry about me because the medication is effective and I've learned a lot about managing my difficulties. My parents are completely informed of my situation and are confident that I will be able to do well here. I also want you to know that you do not have to worry that I will hurt myself.") One other note about home stays for those who take medication: it is extremely important to make sure that you keep your medication safe and out of the way of children or pets.
Finally for those on medication, it is very helpful to carry a list of your medications with the copy of your passport in case you need emergency medical help. Knowing the medication you're taking can make a significant difference to the health professionals in emergency situations.
The Kalamazoo College Counseling Center and Health Center


text: Sabbath Worship Calendar Add to Calendar Add to Timely Calendar Add to Google Add to Outlook Add to Apple Calendar Add to other calendar Export to XML When: May 27, 2023 @ 9:30 am – 12:00 pm Repeats 2023-05-27T09:30:00+10:00 2023-05-27T12:00:00+10:00 Where: 401 Warburton Hwy Wandin North VIC 3139 Australia CHURCH SERVICE We invite you to join us as we worship together every Sabbath (Saturday) morning. Group Bible Study (Sabbath School), 9:30am In Sabbath School we study the Bible together. We have one large group and also small groups which are more intimate and a place to share the experiences of our week with each other. How you participation is entirely up to you. Children, Teens and Youth Sabbath School, 9:30am We have classes for all age groups, where they will be kept busy with songs, crafts, quizzes, games and Bible stories. Main Church Service, 11:00am Our main church service is for all ages. It includes a children's story at the beginning with the main part being a Bible-based sermon. Our music style leans towards the traditional. The service concludes around noon. LOCATION: 401 Warburton Hwy, Wandin Nth