Subject: File No. S7-25-08
From: Ritch McBride

September 19, 2008


Here is a great idea for a permanent rule change:

Every brokerage account would require a separate form just about shorting.

The form would ask permission from the account holder for the brokerage firm to be able to borrow your shares for shorting by others.

The form would explain that those borrowing shares from you are hoping your stock goes down so your are going against your own interests.

The form could also explain that shorters are not able to short stocks unless they can borrow them from people who have already bought the stock.
So the shorters can only do the shorting by pirating the stocks from the buyers. They rely on the buyers doing a positive action so they can do a negative action. The buyer is not reliant on a shorter, whereas the shorter is reliant on the buyer buying first, and this is not fair. The shorter acts as a parasite on the buyer. The buyer does not act as a parasite on the short seller.

The form should be a SEC form so the brokerage firm can't hide the negative consequences of allowing shorting in a lot of small print gobbly gook. No signed form, no shorting of account holders stock. Substantial fines to brokerage firm who breaks this rule.


Ritch McBride