Subject: File No. S7-20-08
From: Santo Criscione
Affiliation: ACAS Shareholder

July 27, 2008

SEC Naked Short Ruling Department,

Please be alert to a recent, on-going short position in American Capital. The symbol is "ACAS". In light of the new naked shorting ruling for 16 select financial stocks, it would be helpful to expand the ruling to all stocks. In my opinion, a review of ACAS's short position, to determine compliance with the SEC's guidlines, would be helpful in restoring confidence that naked shorts ARE actually borrowing shares BEFORE they are allowed to short. There has been some concern that shorts are not complying with that BORROW rule.

Thank you for your consideration.