September 18, 2008
Dear Madam or Sir,
While your pilot study regarding the uptick rule concluded that it "modestly reduce[d] liquidity and do[es] not appear necessary to prevent manipulation, how can you ignore the data (generated in an extreme bear market) that was the original basis for the rule? That data showed in a bear market, shorting on the downtick could drive securities down based on manipulation itself. Why are we ignoring that data? Old data doesn't make it bad data.
We had bear markets when the uptick rule was in place. We had shorting when the uptick rule was in place. The uptick rule did not prevent or limit downward adjustments. The uptick rule did minimize the manipulation.
As an investor in securities on the NYSE, I strongly request you to reinstate the uptick rule.
Best regards,
Jean Duvall
Writing Privately as a U.S. citizen