From: Terral (Terry) W. Chilcoat
Sent: June 18, 2005
To: rule-comments@sec.gov
Subject: File No. 4-500


To whom it may concern;

Re: SEC File No. 4-500. Request for Rulemaking Regarding Member Records of "Short" Positions and Reporting and Public Dissemination of Aggregate Positions by Security.

I want you to make regulators turn on the lights in the dark room of OTCBB trading and protect investors from the menace of hidden short selling in the OTC market. I think this action is now due and is very important to improve the Pink Sheets and OTCBB trading. I know the devastating impact that small companies face when their market is tarnished by the threat of manipulation. I own 525,000 shares of OMOG (I owned over 3m in the past) and I know from personal experience what these unscrupulous market makers and brokers can do. I have my life savings (I am 64) invested in the OTCBB over $100,000.00 - today it is worth only $51,000.00 and I just cannot afford to loose it!

This is causing a crisis in the OTC market today in the lack of short sale position reporting and disclosure for OTC issues. This lack of transparency regarding short selling in the OTC market allows fraudulent acts to go undiscovered and manipulative short sellers to hide and I think it is disgusting.

I think that NASD Rule 3360 should be amended and require NASD broker dealers to maintain a record of total "short" positions in all customer and proprietary firm accounts in all publicly traded equity securities as well as report this information to the NASD for public dissemination (I would love to read it) of the short positions by security. The SEC's action is urgently needed to prevent fraudulent acts, expose market manipulation, promote fair principles of trade and protect investors. It is just the American Way.

SINCERELY

TERRALL (TERRY) W. CHILCOAT

R/A'S OF AMERICA