July 30, 2008
I've read through many of other people's comments here already. I've found that many of them don't fully understand shorting and how extending the emergency order to all stocks would have severe implications on liquidity, and ruin the businesses of many independent traders like myself.
A better solution for all involved would be:
1) To make filings necessary when your short holdings exceed a certain percentage, juts like longs are required to now. (I'm surprised such a rule didn't already exist)
2) Only make the preborrow requirement necessary for overnight holdings. A trader who shorts during the day and buys back his shares by the close has ZERO impact in the price of the stock because they are dealing in small share amounts, and because they are flat at the end of the day.
An extension of the preborrow requirement to all securities will decimate trading volumes, liquidity and will not likely have any net positive effect.
I hope you'll consider my suggestions.