Subject: File No. S7-20-08
From: Barry L. Brewer

July 24, 2008

Short sales should be reported just the same as long sales.
Institutions that are active in short sales should be required to report their short position, at the same time that they are required to settle.
Their institutional trading should be just like any other institution, when a long position Institution sells they report it. They same should hold true to short selling Institutions.
There should be NO NAKED SHORT SELLING allowed, if certificates are not shown by settlement date the sale should be voided.

Barry L. Brewer