Subject: File No. S7-20-08
From: Audis A. Butler, CPA

August 20, 2008

The SEC must make permanent the emergency short sales rules plus they must reinstate the uptick rule requirement. If this is not done short sellors will decimate the financial industry. A short sellor must have to borrow the shares in advance on any short sale. I worked for a major short sellor in the early 1990s - I know from experience how the game is played. If we could have operated then under the rules that we have now we would have been able to make a fortune. Well funded short sellors can overwhelm the long shareholders if the shorts don't have to worry about having to borrow. Plus they can keep pounding the price down if they don't have to worry about the uptick rule. Right now many retirees are getting killed by the shorts pounding their pfd stock prices down. Many are panicking and selling
because of the fear that short sellors are being allowed to create. I agree totally with Jim Cramer's view that the old short sales rules that served us well for 70 yrs must be reinstated. Look at what has happened to LEH, FNM and FRE since the emergency rules were lifted.

Please tell me if the SEC is planning to quickly reinstate
the short sales rules and the uptick rules.

I need to know this before I contact my congressmen.