April 13, 2009
It's hard to imagine how the prior commission could have come to the conclusion that eliminating the existing uptick rule would be fine and dandy by testing in a bull market such as we had in 1999. Obviously the results would be meaningless in today's casino like market environment.
My comment would be YES, we need to reimplement the uptick rule and the sooner the better. We should not leave the market without at least a temporary rule for the next 60 days while the Treasury Secretary reports the results of the bank Stress Test. This is a critical time period.
Please consider putting the existing uptick rule back in place immediately to avoid further panic selling and bear raids that we certainly occur while you wait for comments.
Finally, YES, again, implement a two tier approach with both the original Uptick Rule and a Circuit Breaker added.
Thank you and please act asap.