July 9, 2008
Dear Chairman Cox,
Re: Comments on Proposed Amendments to Regulation SHO
File No S7-19-07
I appreciate the opportunity to provide comments on the Commissions proposed amendments to Regulation SHO.
As a shareholder in various companies I have become painfully aware of the unjust/illegal naked shorting actions occurring on Wall Street and the world.
The illegal manipulations that occur daily is such a blatant abuse it is shameful. A market maker should be able to locate sales before a short sale is done.
In support of the Commissions proposed elimination of Regulation SHOs options market maker exception I ask the Commission to complete the administrative steps to make this change as quickly as possible. Otherwise it appears the SEC is allowing counterfeiting and common thievery of the hardworking American people as the options market maker exception has been a well known tool of manipulation.
It has been some reassurance that the Commissions recent action to strengthen Regulation SHO through the elimination of Regulation SHOs grandfather provision. It has been refreshing in the past several months to hear Chairman Cox personally speak about the abuses of naked short selling and the need to end this manipulative practice. I remain concerned that, despite the Commissions recent efforts and Chairman Coxs public comments, these abuses continue.
I strongly urge the SEC to eliminate the “grandfather” provision of SHO Regulation.
The Commission should issue and complete these two critical components of effective Regulation SHO reform. By eliminating the options market maker exception and the grandfather provision the Regulation SHO will be a better tool. These changes alone will help solve the problem that results in continued naked short selling and failures-to-deliver but it is a solid start and will be a refreshing change!
(1) Impose in Regulation SHO a requirement of a firm location of shares to be borrowed before a short sale can be executed.
(2) enable transparency by requiring timely disclosure of the volume of failures-to-deliver shares of companies on the Regulation SHO threshold list.