Subject: File No. S7-12-06
From: P. E. Bursley
Affiliation: Certified Credit Counselor, ret.

August 7, 2006

I no longer trade securities.

What substantial holdings I do have are held in certificate form and kept safely away from Wall Street in my banks vault.

Until the SEC, Congress, the Dept. of Justice, etc. enforce laws against naked short selling and impose serious penalties (heavy fines, loss of securities licenses, and, yes, hard prison time), I will no longer invest in Wall Street. The triumph of monied interests over the rule of law, ethics and integrity is no triumph. It must cease.

I am far from alone in this sentiment.

The SEC must:

1. Eliminate the grandfather clause.
2. Narrow the market maker exception (options market makers).
3. Require a mandatory pre-borrow for all short sales with no exceptions.

Do not provide some kind of "loophole" that does not guarantee actual delivery of securities. I repeat "Delivery with no exceptions"

As the International Association of Small Broker Dealers and Advisors said so succinctly, "liquidity based on fails is a prescription for systemic failure and unfairness to issuers."

Why this fraudulent activity has been allowed to be perpetuated for so long is beyond me. The possible reasons being bantered about are quite unsettling, to say the least, and certainly cast a sinister pall over the SEC.

Integrity, confidence and trust in the SEC and Wall Street must be restored. That means integrity, confidence and trust from the investing public, not from the entrenched powers that be.

Thank you for your time.