Subject: File No. S7-08-08
From: Herbert J Lock
Affiliation: Chief Investment Officer Investor Relations for MBT Financial Corp (MBTF)

May 19, 2008

MBT Financial Corp trades on the NASDAQ Global Select Mkt
under the symbol MBTF. We started trading on NASDAQ (Nat'l)
5-1-03 and became a part of the Russell 2000 also in 2003.
We came off the Russell 2000 June of 2007. In May 2007 our
Short Interest (SI) hit 746,565 shares of 16,535,307 shares
outstanding. Our peak was June of 2007 at 922,567 shares SI. During that run up period we were on the Threshold
list so many times, I thought we should be renamed MBT
Financial Threshold Corp. Our Short Interest Ratio hit over 30 on 10-13-06 and 4-13-07. Do I believe we had some Naked Shorts during that period, absolutely yes. I support
any regulatory effort on our behalf to stop the practice.
I would also like to see the SEC take a look at price manipulation for the many issuers like MBTF that trade less than 25,000 shares a day on average. Some of our closes
have caused us to question whether there has been an effort
to trade the stock down at the end of the day. Most recently FINRA has reviewed our 1-29-08 close. I have asked
NASDAQ to consider how their Closing Cross procedures might
be manipulated to move the price down or up.
The SEC Rule that prohibits us from buying back our stock
in the last half hour of trading should also be reviewed as
it impacts a low volume stock like MBTF. We have a published Stock Buy Back in place. I have on numerous occasions watched a series of 100 share trades at the end of the day move the stock dramatically down for a lack of "buyers". Buy Backs can't be used to support or enhance a price but,are the shareholders getting a distorted view of the value of their equity in the above noted instances?
We understand that the best thing MBTF can do for our shareholders is to improve profits. However, your efforts to stop manipulation of prices via Naked Shorts or other means--is greatly appreciated.

Herbert J. Lock