From: firstname.lastname@example.org [email@example.com]
March 3, 2004
Re: Reg SHO
Dear Commission Members:
I am pleased to see rules which further improve the trading efficiency in the market place.
My interest in commenting stems from my desire for more disclosure on who are the "shorts" that comprise short interest. The NYSE, AMEX & NASDAQ report on a monthly basis the short interest of each listed company. My experience leads me to believe that this number may not include all of the actual short interest. As a public company, I am able to see the "longs" via the 13F and 13G filings. I would like to see the equivalent short holdings also filed in the 13F and 13G filings.
"Shorts" play an important role in the financial markets in creating liquidity, but "shorts" are unfairly able to hide behind the lack of disclosure. This allows them to have a hidden agenda to accomplish their mission in moving a stock down. Obviously, my role is as a fiduciary to the "long" shareholders, but I feel equal disclosure is important component to having an efficiently price security.
Thank you for providing a forum to respond.
Philip A. Hadley