Subject: File No. S7-12-06
From: Tim M McCaffrey

April 4, 2007

Having invested in several companies and seeing my investments harmed by the "grandfathering" of FTD's and the practice of naked short selling, it's way beyond time for the SEC to act to eliminate this error.
The 'grandfather clause' of Reg SHO is nothing more than the SEC blessing the illegal activity of numerous brokers and market makers who have sold shares they did not have or borrow. The practice of naked short selling is the counterfeiting of securities and is greatly harming our securities markets and causing many of us to lose faith in the integrity of our markets and government agencies tasked with our protection.
It is time for the SEC to fulfill its mission of protecting the rights and investments of the investors...especially the small American investors who have put their trust and hard-earned money into our financial markets.
Act what's right, and not necessarily easy. Eliminate the 'grandfather clause'