Subject: File No. S7-12-06

March 27, 2007

Not only is the "Grandfather Clause" of regulation SHO, or should we say, "NO SHO" Illegal, it is also Unconstitutional.

chairman cox: He called the SEC's past efforts to address short-selling abuses "inadequate" since some pre-exisiting short sales were exempted from stricter rules by a "grandfather" clause, and said ending the exemption "will .....ending the exemption "will further tighten" short sales and help eliminate abuses