September 29, 2009
I am apposed to the Circuit Breaker approach. The Proposal to only allow shorting at a price above the national best bid price would be better, but probably not very effective. The SEC is supposed to provide a level playing field for investors, not a Ski Slope for big Hedgefunds and Day Traders. These people would be the only ones that would know what the best bid price was. A truly effective rule requires a sale at a higher price, not just a Level II bid. Which is more important assuring big profit potentials in a down market for large traders or preventing huge losses in investors IRA's, 401K's, and long term investments caused by intentional manipulation? Unregulated Short selling is ripe for collusion as well, with coordinated shorting. Look at how stock prices are manipulated for Options expiration. Finally, When firms insist on keeping what they are doing a secret, it's a good bet they are doing something wrong. All Short Sale volume should be shown as a separate category. It should not be included in regular sales volume. Please, promote stability for investors and help restore confidence in the Market. Give us a real Up-Tick Rule