April 10, 2009
To the Securities and Exchange Commission,
As I have stated in my previous comments to the SEC
December 12, 2006
We would like to express our concern over the proposed rule change on the up tick rule. Though studies have shown that there were no material effect on stock prices in the study, It is quite obvious that this will lead to bear raids on stocks in the future, especially during a changing economic environment.
October 7, 2008
I think it is imperative for the success of the market that the commission considers reinstating the up tick rule with up tick being every .10 cents from the last trade, not every penny.
In light of these comments, I would only make a slight adjustment, instead of every .10 cents I would move it to every .o5 cents. And no circuit breakers.
Further I feel it's a farce when people say that by moving the up-tick out to 5 cents, it would be a ban on short sellers. It use to be an eighth or a quarter, depending on the bid and ask, before we went to decimals. And that seemed to work quite well for many decades.
In pursuit of price stability and investors confidence.
Sincerely,
Franco A. Mortarotti
Zermatt Capital Management+