Subject: File No. S7-08-09
From: Mark Nielson, Ph.D.

August 21, 2009

Regarding uncovered short sales:

We believe naked short sales (NSS)
may serve price discovery and are therefore
worthwhile. The arguments against them
we feel are weak for the following two reasons:

FIRST: So long as all participants are aware
of the naked short sale then no injury.
No injury no economic damage.

SECOND: the naked short selling
is really no different than financial futures
in which there is nothing more than a contract
changing hands.

Sincerely, Mark Nielson PhD
MacroEcon LLC