July 17, 2006
Regarding the proposed Reg SHO amendments:
Please eliminate the grandfather provision in Rule 203(b)(3)(i).
Please limit the duration of the options market maker exception in Rule 203(b)(3)(ii) to the later of 13 consecutive settlement days from the date on which the security becomes a threshold security or the options position expires or is liquidated.
Please tighten the locate requirements for borrowing shares. The same pool of shares is being pledged to multiple borrowers to satisfy the current "locate" requirements. That's one of the many ways more than 100% of the outstanding shares can be shorted. It's counterfeiting. It's fraudulent. This is the only way to stop it. Make requirements very strict, fully verifiable with no reliance on "belief." This safeguards that the same pool of shares are not concurrently used to satisfy the locate requirements of multiple parties.
Please protect investors, not market makers, specialist, and other Wall Street professionals. If the little guy is protected and treated fairly, by definition, everyone including all Wall Street professionals are also treated and trade fairly.
Thank you for your time,
Average Jane Doe Investor
Disclaimer: The above comments were copied and modified by me from an investor message board post. I in no way take credit for the wording. I do agree 100% with the sentiment and the suggestions and felt it worth sending in a separate letter of my own so that the SEC will understand how important this is.