Subject: File No. S7-08-09
From: Ralph B. Ritson
Affiliation: Registered Investment Adviser

May 4, 2009

Please reinstate the traditional form of the 'uptick' rule
and eliminate naked short selling of any securities. Also
would like reinstatement of the provisions of Glass-Steagel
to separate banking investment banking and insurance and
to prohibit ownership of more than one element of these
forms of organization by any one entity, including related
companies, subsidiaries, partnerships or holding company
components. It is essential that the retail investor be safe from the raids conducted by short sellers since 2007,
and which left equity mutual funds defenseless from those raids. Some review should also be conducted on
the deleterious effect quantum trading programms have
on market stability. The 'uptick' rule will not be sufficient to stop computerized short selling assaults
on companies showing high daily price spreads as these
programs create the downdrafts which drove GE, WFC,
CAT and many other stocks to their current lows.