Subject: File No. S7-20-08
From: Jon K Stucker
Affiliation: Financial Consultant, Portfolio Manager

July 30, 2008

Dear SEC, Christopher Cox,

The new rules to inforce against Naked Shorting, requiring an immediate locate on shares BEFORE they can be shorted obviously works and MUST be extended to all securities
The up tick rule desparately needs to be reinstated in the stronger 5 to 10 cent format you have recently outlined as well.
The 'so called' thorough testing that preceeded the lifting of the up tick rule is completely unfounded. The testing occurred during a bull market and the full market was unaware of the test. Those that were let in on the test would have been on their best behavior as well.
This past year has been the REAL test for the impact of the lifting of the uptick rule and look at the fallout
Countless Bear Raids have resulted in a financial crisis with most banks and financials down 60% or more, let alone those who have been wiped out...Bear Stearns, IndyMac, Thornburg, Countrywide, etc. etc.
When any company announces a need to raise capital, the SEC should ban shorting during the period that the firm is raising the capital...look at the impact of MER, C, LEH, etc. as they were driven down and then forced to grossly dilute the shareholders.
Short selling does not help the stock holders, the companies who list their shares, or the investment community at large. It only has increased volatility, which helps the NYSE order flow and profits the Institutions, Hedge Funds, and worse yet Soveriegn Wealth Funds, many of which would love to destroy our Banking System.
Please act before more companies fall victim.

Jon Keith Stucker
RBC Wealth Management
Senior Vice President
Branch Director
Portfolio Manager