September 11, 2007
Ms. Nancy M. Morris, Secretary
Securities and Exchange Commission
100 F. Street, NE
Washington, DC 20549-1090
Re: Comments on Proposed Amendments to Regulation SHO
File No S7-19-07
Dear Secretary Morris:
I am writing as a concerned shareholder of a company that has been on the Reg SHO list for a long time. I appreciate the opportunity to provide comments on the Commissions proposed amendments to Regulation SHO. I commend Chairman Cox for personally taking actions to put an end to manipulative and fraudulent practices against what I am sure is significant pressure otherwise.
While I have been very displeased at the length of time that it has taken to strengthen Reg SHO, I comment the recent action to eliminate the Grandfather provision. The reasoning for this provision to be here in the first place is questionable, but a am glad it is being eliminated.
I strongly support the Commissions proposed elimination of Regulation SHOs options market maker exception. The options market maker exception has been a well known tool of manipulation and must be eliminated promptly to ensure a level playing field for public companies and shareholders.
I also request the Commission impose in Regulation SHO a requirement of a firm location of shares to be borrowed before a short sale can be executed, and enable transparency by requiring timely disclosure of the volume of failures-to-deliver shares of companies on the Regulation SHO threshold list.
cc: Christopher Cox, Chairman, U.S. Securities and Exchange Commission
Paul S. Atkins, Commissioner, U.S. Securities and Exchange Commission
Roel C. Campos, Commissioner, U.S. Securities and Exchange Commission
Kathleen L. Casey, Commissioner, U.S. Securities and Exchange Commission
Annette L. Nazareth, Commissioner, U.S. Securities and Exchange Commission