Subject: File No. 4-627
From: Bruce H McDonald

May 31, 2011

The fact that you are asking for comment suggest that due to the millions of complaints to your agency, you are engaging in your usual 1-2 year stall tactic.

You, without public comment, know that you have been unable to enforce naked short selling and it has only gotten worse with the advent of HFT's. 70% of all volume is now done thru HFT's whose primary tools are naked short selling, front running transactions, limiting true price discover and algorithmically and methodically stealing any and all "equity" from the markets of retail investors, mutual funds and investors retirement assets.

There is no true liquidity provided by the short sellers and HFT's because they provide liquidity only when they are creating the volatilty they need to extract profits for themselves (and most likely other who would co-conspire to rig markets). Flash crashes could not happen if their was such great "liquidity" provided. You also know that flash crashes happen as a result of their removal of liquidity at will and with intention. Flash crashes are the ultimate end game of those who are the naked short provides them with the ultimate "cover".

I think simply requiring short positions really does not solve your problems. You do not enforce Reg Sho did not and could not even locate nor prosecute parties responsible for the flash crash.

Love your new program where you have limited the ability of investors to even complain


Just because the short selling might get a little more disclosure as a result of Dodd bill...doesn't mean you have any abiity to do anything with the information.

You have already proven yourself ineffective in doing so.

Can wait to see your blue ribbon panel that you organize to discuss the results of your "public comment"

Why not just ask for Goldman Sachs, all HFT's and hedge funds(both onshore and offshore) to make their comments public so the congress can just adopt their version right now and save the 1 year of studying the problem.