Subject: SEC File No. 4-500

September 25, 2005

Dear S.E.C.

I am writing this letter of support for SEC File No. 4-500. Request for Rulemaking Regarding member Records of "Short" Positions and Reporting and Public Dissemination of Aggregate Positions by Security.

Without this rule change investors and securities regulators are blind to any short selling activity in Pink Sheets and OTCBB stocks. I would like for you to know that the lack of short sale information in these securities is unacceptable and I am requesting that you change NASD Rule 3360 immediately.

Sincerely,

Anthony M. Giannini