April 22, 2009
SIRS:
YOUR PROPOSAL DOES NOT GO FAR ENOUGH, NOR SAFEGUARD STOCKHOLDERS ADVERSELY AFFECTED BY "NAKED SHORT SELLERS". A SPECIFIC RULE REGARDING "NAKED SHORT SELLING" BEING PROHIBITED SHOULD BE INITIATED AND A CIVIL AND CRIMINAL PENALTY ESTABLISHED FOR VIOLATORS. ALSO, THE CAPITAL REQUIREMENTS FOR SELLING STOCK SHORT BY ANY METHOD USING MARGIN ACCOUNTS SHOULD BE INCREASED TO THE FULL PRICE OF THE STOCK BEING HELD IN THE MARGIN ACCOUNT. ALSO, THE USE OF OPTIONS, WHETHER IN COMBINATION OR OTHERWISE, TO EFFECT A SHORT SALE OF THE UNDERLYING STOCK SHOULD BE INCREASED.
THE S.E.C. IS TAKING A KIDS GLOVE APPROACH. THE APPROACH SHOULD BE GLOVES OFF.
THE S.E.C.'s INEPTNESS IS A CONTRIBUTING FACTOR IN THE ECONOMIC PROBLEMS AND THE FINANCIAL/STOCK EXCHANGE SYSTEMS. GET IT RIGHT OR GET OUT PERIOD AND LET SOMEONE WHO KNOWS THE FACTS RUN THE SHOW.
CHUCK JONES