August 7, 2006
From: James Ellis
Subject: File S7-12-06
All stock trades should settle in 3 days or less.
Future SEC emphasis should be placed on a goal of computerizing all exchanges and settling all trades before the opening of the next business day.
In my opinion the position of market maker should be phased out as the computerization of the exchanges is implemented.
In my opinion, the broker representing the seller in a short sale should be held responsible for the borrow of any and all shares to be shorted. All short shares should be delivered within 3 days or be bought in at market open on the 4th day and delivered to buyer by the close of business on the same day.
All foreign brokers should be held to the same requirements as domestic brokers.
The grandfathering of past fails to deliver should be eliminated altogether.
Any seller of stock listed on any of the major exchanges that repeatedly fails to deliver shares that have been paid for should be referred to the Justice Department for possible prosecution under existing guidelines mandated by Rule 17-A of the 1934 Securities Exchange Act.