Subject: File No. S7-20-08
From: Constance F. Drapeau
Affiliation: Retired Stock Broker

July 23, 2008

Your elimination of the uptick rule was an enormous mistake. Your "economic study" covering 2005 to 2007 was during a period of tranquility in the markets and of no use at all in evaluating short selling during an extremely volatile market. At the VERY LEAST you need to reinstate that rule. Furthermore you need to keep the emergency order in effect until you have the time to investigate the naked short selling. Investigating naked short selling after a company has been destroyed is of no value. Keep the emergency rule in place until you have thoroughly investigated that aspect of the bear runs that have been taking place.

May I remind you that without a viable financial system your jobs are in jeopardy as well.