Subject: File No. 4-627
From: James Ballard

June 6, 2011

Please improve short sale reporting as much as possible. Personnaly, I don't think we should allow short selling at all since it is the sale of a share of stock that really does not exist (2 people should not be allowed to hold 1 share of stock - certainly without them knowing with full disclosure). To this end, anything that makes short selling more transparent is good in my opinion.

Because of the technologies available today as it pertains to market trading, allowing short selling is more harmful than helpful (by far) to our investing markets. It was different a long time ago, when trades were slower and there was less complete information available to the large investors.

Stock investing should have the concept of Supply and Demand as a realiable fundamtental. Shorting stocks, especially when not disclosed, makes Supply and Demand concepts invalid (shorts can create large supply that really doesn't exist). Some may argue that shorting stock in some ways supports market issues, such as supply and demand. Those arguments are a stretch at best.

For those who think that investors need to be allowed to take short positions in stocks, the mechanism to do this is the Option concepts of Calls and Puts.