Subject: Comment Letter for File Number 4-848 Petition for Rulemaking to amend Reg SHO to require pre-borrows for all short sales, impose fees for Fails To Deliver and eliminate market maker exceptions
From: Shane Thrasher
Affiliation:

Mar. 18, 2025

I am writing in support of the We The Investors petition for rulemaking to amend Reg SHO. These changes include: 

Rule 203: Require all short sales, without exception, to be backed by a confirmed borrow of securities prior to execution. Rule 204: Impose escalating monetary fees or fines for FTDs, applicable to all market participants, with proceeds supporting enforcement. Rule 204: Eliminate all market maker exceptions to locate and close-out requirements, ensuring uniform settlement timelines. 
The reasons for these changes include: 
US markets have a problem - short selling and failing to deliver is distorting supply and demand in markets, impairing the price discovery process. The persistence of FTDs introduces systemic risk. Enforcement actions have demonstrated that loopholes are being abused. 
Thank you for your time. 


Shane Thrasher