May 5, 2009
Dear Ms. Shapiro:
Thank you for giving us the opportunity to comment on the issue of short selling. While I believe that orderly and legitimate short selling is very good for the market, I do not agree that the current means of monotoring and administering the oversight of short selling practices is effective. Specifically the issue of Naked Short Selling and the exceptions and manipulation of the 3 day delivery rule. The fact that FTD's continue to be massive and that intermediaries are allowed to manipulate the market so that the shares required to be borrowed to validate short sales are never borrowed.
I believe this issue is more important to managing the market in the interests of investors than the uptick rule or some kind of market trading trigger. I listened to the discussion of May 5 and was very disappointed that the issue of Naked Short Sales was not discussed. I do not understand how FTD and NSS issues are not central to this discussion.
Thank you for the opportunity to comment.
Joseph F Stone