Subject: File No. S7-12-06
From: John A Studer
Affiliation: Electrical Engineer

March 29, 2007

If there is a loophole in the rules for short selling which allows for short sales, and then allows or gives little or no fine for not delivering the stock to complete the short sale, this loophole should be closed immediately. I am not a securities expert, but it is plain to see that massive "naked" short sales without having to deliver the shares after a reasonable period of say a few days is outright fraud and market manipulation. Legitimate short sales where the shares are available and delivered is healthy for a market as the true short seller is taking an equal financial risk as a long might take in a stock. Please close any loophole which allows "naked" short selling. After closing this loophole vigorously prosecute anyone who blatantly continues to conduct this fradulent practice.