Subject: File No. 4-590
From: Robert Bardwell

November 22, 2009

I believe there is still a proliferation of naked shorting being done in stocks priced less than one dollar. The brokers involved are using the ex-clearing method to hide their trades from regulators.Using ex-clearing, brokers can skirt the regulated settlement systems and can deal directly with each other in private. I think ex-trading should be deemed illegal and eliminated, if it is not, there will continue to be naked shorting and abuse of small corporations.