From: Allan F. Treffry, Esq. []
Sent: December 15, 2003
Subject: File No. S7-23-03

   RE: Proposed Regulation SHO

Dear SEC,

I know that your agency and I have had many cross words regarding what I have asserted to you as your agency's apathy regarding the illegal naked -selling of stocks I have invested in (namely PCBM). Those cross words have been especially harsh with particular SEC officers. However, I now wish to commend you on the Proposed Regulation SHO, in the hopes that you will strictly enforce this regulation and clean up the market and returning integrity to the market at all investment levels. The application of this regulation must be across the board, not just on larger cap stocks, as stealing money from Americans and from our economy, at whatever level, is financially devastating to both individuals and to the American economy. Think about it, what is the difference if the thieves are permitted to illegally naked short and steal from only our investors in micro-cap companies. They are still stealing from America and from Americans.

Based upon my own reading, I understand that 3-4 TRILLION dollars is stolen from our economy each year by those who basically counterfeit shares of stock, in the hopes of companies they short being driven out of busines and then making the unjust windfall profit. If any person were to counterfeit money, the FBI would have them in shackles immediately upon discovery of this nefarious act. Yet similar conduct, regarding selling shares that are not in existence, is a plague upon our economy, robbing good, honest Americans of those dreams ordinary available that have made our nation the envy of the world.

Our entire GNP is between 9-10 TRILLION dollars, meaning that these thieves are leaching out of the country between 33%- 40% of the nations GNP every year. I have read that these stolen funds, via illegal naked shorting, ends up funding everything form organized criminal activity to terrorists who use the money to attack our troops and our citizens, both abroad and domestically. What could we do with an extra 3-4 TRILLION dollars in the economy each year? Congress just approved 87 billion dollars to fund the war effort and this allocation was painful. Just imagine what a multiple of 50 of those funds remaining in our economy each year could do for America? What would such funds do for small businesses? For people who need jobs? For government to reduce the deficit? To aid the poor and sick? The possibilities are almost unlimited.

America needs your dedication, your wisdom and your unwavering help to make this situation right. Just as the military is working so hard to overcome terrorism in its' physical manifestation, you must act as the protectors of our economy. You are on the front line of defense for America to stop the evil people from stealing money from our economy and from our citizens to fund their criminal activities and those very attacks we fear the most. I implore you to rise above all other possible motivations and or distractions, policies, or anything else that might dissuade your actions, to make use of Regulation SHO and make a difference.

You are uniquely positioned to help make America stronger and more importantly a safer place to live. I pray you act with wisdom commensurate to your authority.


Allan F. Treffry, Esq.