February 21, 2010
I would simply like to state that bringing back the "uptick" rule for shorting stocks is an absolute must in making sure that our markets are more stable and less subject to manipulation. Much as the suspension of the "mark to market" accounting rule provided greater stability in our markets by ending the senseless spiral of low prices begetting even lower prices in the bond markets, so will the "uptick" rule stop the potential for this madness in the equities markets.
As long as you're looking at these issues, please also immediately ban credit default swaps, or at a minimum, ensure that their use is limited to those with a true "insurable interest." Allowing these instruments to be bought and sold by those with no actual underlying risk to an entity is somewhat akin to morticians and doctors buying life insurance on terminally ill patients.
Further, as evidenced by the events of 2008, the practice of trading CDS's has real effects on the entities they are linked to. One way to describe it is to imagine if bets placed in Las Vegas on the Super Bowl actually had an impact on the outcome of the game. Surely, this wouldn't be allowed. In the CDS market, the direction and size of the "bets" directly influences the outcome of the "game", and this should never happen in our markets. The SEC has the power and obligation to prevent this behavior, and I ask you to do so.