Subject: File No. S7-08-09
From: robert hall

May 28, 2009

First I oppose any concentration of market oversight by any single agency, the SEC, and the Federal Reserve Bank should remain as separate entities but by all means should cooperate in keeping markets fair and safe for investors.

I believe whole heartedly in free market capitalism and that regulation should be limited to whatever is needed so as to keep things running smoothly.

That said it can be noted that in addition to the uptick rule, the vast increase in market volatility seen from a technical view arose as a result of lobbies by Citi and Travelers just before 1999 with the repeal of Glass-Steagal (Gramm,Leach,Bliley), then the subsequent "daytrader Rule, Federal Reserve regulation T enacted in 2001 sought to blame daytraders for the problems largley created by the then newly formed mega capital infused (or leveraged)-hedge funds. That is of course all history now and the market has grown such that we could possibly impede the forward growth and stability of the economy with any new restrictions that would revert fully back to Glass-Stegal, however the problem with unrestricted leverage from the larger players, and impositions on the smaller investors does pose question to what can be done that works to keep the balance in markets overall sustainable for the future.

Personally I am somewhat old fashioned, I have never sold any security that I had not previously purchased, to me that's just common sense. I understand that markets work quite differently from my simple perspective and admittedly it has not always been profitable for me to buy and hold long term as is my goal, but at the least I simply buy and hold as long as possible. So for me the uptick really doesn't matter so much as overall long term stability in markets, I think the big changes I reference from 1999 and 2001 address those larger issues. It is up to both the SEC and the Federal Reserve to determine if they need any modification since beyond my own humble opinion I am powerless to affect.