Subject: S7-08-08

May 5, 2009

File Number S7-08-08

Naked shorts provide a dangerous mechanism where my IRA fund manager can “rent” my shares, and thereby looking responsible, without the actual transaction being tested. On the short side, associates can pile up shorts and drive the price down.

Not only should there be an uptick rule, but a transaction fee, like a short registration fee of about .00001%. This fee associates the short sale with the borrowed stock, and exposes the transaction to scrutiny.

Richard Hein