Subject: File No. S7-31-08
From: Bob R. Kneisley, APR
Affiliation: Author:

December 2, 2008

Let's go back to the "uptick rule" and require reporting on all short sales if the "uptick rule" is not re-established.

Also, the SEC should require disclosure of all internal trading and clearing costs in the prospectus of all mutual funds to better protect investors.

In addition, there needs to be full disclosure of the "survivorship bias" created by closing or merging mutual funds. There seems to have been a dramatic increase in such the detriment of all mutual fund investors.

Thanks for your consideration.

Respectfully submitted,

Bob Kneisley