When World Trade Center families and others agreed to express their concerns together last night at an armory on Park Avenue, they were motivated by a deadline. Only days remain to submit comments on the proposed rules and regulations of the fund set up by the federal government to compensate those whose lives and livelihoods were devastated on Sept. 11. The rules are flawed, and we urge the White House, the Justice Department and Congress to act now to change them.

On Sept. 11, 133 of our employees woke up and went to work, never to return home. Each of our companies was located in Two World Trade Center — Keefe, Bruyette & Woods on the 88th and 89th floors and Sandler O'Neill on the 104th floor. Our firms were among a group of companies with offices in the World Trade Center whose rosters of employees read like a Who's Who of the financial sector of the economy. They were exactly the kind of people Osama bin Laden and Al Qaeda wanted to target. Their families are now dealing with both grief and enormous financial challenges.

Congress quickly passed laws intended to protect the airline industry and limit the liability of other potential defendants while giving the victims' families proper compensation for their losses. The intent was to eliminate the need for costly, uncertain and time-consuming lawsuits. But the rules and regulations announced on Dec. 20 by Kenneth Feinberg, special master in the case, not only are unfair, but directly conflict with that intent. They do not present an adequate alternative to litigation.

To calculate the compensation awards, Mr. Feinberg uses national economic statistics and data derived from the public sector, while most victims worked in the private sector and in the high cost-of-living regions of New York and Washington. Many victims were in their 20's and 30's, in the early stages of promising careers, and their potential is not adequately taken into account. Also, the rules essentially create a ceiling on the awards available to many families, assuming they have other resources. Economic loss, not need, should be the determinant of compensation. And the regulations deduct certain benefits, like life insurance and pensions, from compensation awards. Such limitations on awards have never been found in our American legal system.

The proposed rules turn the Congressional legislation on its head, unbalancing it by reducing likely awards to levels far below the economic losses suffered by victims and their families while protecting airlines and others that might be sued.

The decision to file a claim requires a family to make a leap of faith and place its trust in Mr. Feinberg. By submitting a claim, families are waiving their right to litigation. They have no appeal if the system does not treat them fairly.

As representatives of companies directly and tragically affected by the terrorist attacks, we are proud and grateful for the sympathetic and concerned response to the victims from the White House, Congress and elected officials at all levels, both at home and abroad. However, we are deeply concerned that the implementation of the Victims Compensation Fund is entirely inconsistent with this response.

Fred Price is the chief operating officer of Sandler O'Neill & Partners. Mitch Kleinman is general counsel of Keefe, Bruyette & Woods. Both companies are financial firms.