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: Joseph Pazhman
Affiliation:

Apr. 1, 2025

I urge the Commission to move quickly on this petition, and to propose these needed amendments. Removing these regulatory loopholes will help eliminate waste and remove opportunities for potential fraud or abuse. Simply put, eliminating these Reg SHO carve-outs will simplify markets and make them more efficient. These changes help me, and individual investors like me, regain a lost confidence by ensuring a settlement system that's transparent, straightforward, and one that all investors can trust. 



Respectfully, 
Joseph Pazhman