Subject: File No. S7-31-08
From: nan krish

October 31, 2008


I still don't understand what harm immediate public disclosure of short positions by investment managers would cause to the investment manager firm. If I am long on a stock and I learn of the short position on the stock by the investment manager what am I going to do ? Execute him?
Or if I am a competing hedge fund manager and learn of the short strategy on stocks by my competitor am I going to play the same strategy? If I did then there currently must exist hedge fund managers who are always right 100% and are billionaires and trillionaires which is not the case.

What the Hedge fund managers are most likely afraid of is with the public disclosure of their short positions by SEC they come under public scrutiny on all the ILLEGAL AND FRAUD ACTS they have been doing in the past and want to continue to do in the future outside of public scrutiny. If I was a billionaire Hedge fund manager and am honest and play by SEC legal rules on investments I would not mind if my short positions on stocks are disclosed. But if I was dishonest and built short positions in advance and twisted an analyst's arm (because of my big money)or the analyst acted in collusion with me on illegal acts like release of timely rumor news that I fed him and that helped my short position then I would be afraid of public disclosure of my short positions because I would be afraid some investor with the opposite investment position will start investigating and learn of my illegal and fraudulent act so I would like to stay under the radar.

Let SEC try disclosing all short positions by hedge fund managers immediately and it will find that there was no harm to anybody and all investors and traders went about their business as usual.

When U.S embarked on the mission to moon NASA and the astronauts knew the men might never return back to earth. So did NASA stop the mission? No, they sent the astronauts to the moon, landed them and safely returned them back to earth.