July 9, 2008
The Grandfather clause in Reg SHO is patently unfair to all but those who game the system; for them itís green light to keep ill-gotten lucre and continue the charade. All we small investors request is full transparency and an even field. A good start would be to open the books of the DTCC & lose the skewed stock borrow program that facilitates counterfeiting of market securities. Call counterfeiting what you will; failures to deliver, naked shorts, phantom shares, desk trades, ex-clearing, settlement failures, whatever. Counterfeiting by any other name is counterfeiting. Why another comment period is needed is beyond me. What part of the truth does the SEC fail to understand?