Subject: File No. S7-12-06
From: William H Crowell

April 4, 2007

-Regulation SHO is not working as is evidened by the long list of Fails to Deliver found on
The grandfather clause associated with regulation SHO is illegal. The SEC is not in a position to write it's own rules, only to inforce the rules provided to them by congress.
Allowing the grandfather rule at all is allowing criminals to get away with the counterfeiting of securities. This act is no less criminal than the counterfeiting of money.
The SEC needs to be held accountable to inforce the rules and not make them up as they go along. This is no different than children playing a game and changing the rules as they go along to insure victory.
Revoke the grandfather clause. The public is becoming more aware every day of the SEC's short comings. It makes me wonder whos side you are on. Based on the compensation packages passed out on Wall Street this past year, it appears the SEC is not on the side of the investing public but instead on the side of criminal activity.
Do your job and enforce the rules. We know who you are and we will force accountablity if you do not.
Best Regards,
Bill Crowell

CC: Sentator Chris Dodd - Chairman of the Senete Banking Committee.