Subject: File No. S7-19-07
From: Shawn M. Loddy, MIBA
Affiliation: Investment Advisor Rep.

July 18, 2008

I personally manage and consult on over $45 million in retirement and brokerage accounts. I am an active money manager and am in the makets on a daily basis buying and selling stocks and bonds.

The first task that SHO does not do, which is mission critical to the task of stopping naked short selling, is to put the onus of finding the stock and virfiying its availability by the Broker/Dealer before the stock is allowed to be barrowed by a client. In my mind this is the only way to make sure that naked short selling is not allowed to happen. IN OTHER WORDS ACCOUNTABILITY.

The Second item SHO does not address is Recourse.
When securities fail to deliver there needs to be a method of recourse by the B/D against any parities failing to deliver. Wheather it is simply reporting the incident or something more direct is up to congress. The more direct the action is will have an impact on how effective the system is in stopping naked short selling.