Subject: File No. S7-08-09
From: Bruce Kitchin

May 30, 2009

I believe that the up-tick rule which has been in place since the 1930's until the ill-advised change in 2007 should be restored as is. The rules served us well for some 70 years and within a year of its abolition, a recessionary trend in the market turn into a disaster of world proportions. I also note that most opponents of restoring the rule have an obvious self-interest in it that negates the useful of their analysis or who are academics who usually base their results on data obtained during a strongly rising market and do not consider the data that we have so painfully seen in the recent crash. This is by no means the cure-all or the answer to all that went wrong but I firmly believe that the abolition of this rule had the clear effect of magnifying the size of the problem.