Subject: File No. S7-08-09
From: Tom Levin
Affiliation: Portfolio Management Director

February 20, 2010

I would simply suggest we return to the rules that were in force for many years.

1. You can only short on an uptick in the stock
2. ETF's should NOT be exempt from this rule
3. No short sales can occur without PRIOR stock loan verification. ALL naked short sellers will be prosecuted.

On another matter we need to focus on regulation for the CDS market as soon as possible. It is still the wild west and needs to be internationally regulated.

Thank you for the forum.