Subject: File No. S7-08-08
From: Guillaume Cloutier

July 25, 2008

Naked short selling have plague the market for quite some times, nobody really knows the extend of its effect on the market. The only thing for sure is that it have one, and it's not positive. Largely favoring big corporation to the expense of the individual investor. It permit manipulative traders to great gap in the spread between trades, to clear the book, and to trigger stop loss order placed at different broker. Many will not admit the practice, but some firms will look at their own clients account for those stop loss orders, and can assume that of the overall market, it just mathematics

I've been working in the industry for quite some time now, and I've seen, and heard about, many many many investment firms doing anything imaginable, to the limits of what is acceptable by laws, to make money always at the expense of the customers, even theirs. Regulations are flawed, I know it as facts, I work with them everyday. The methods to monitor those rules are flawed too, even those of which are not published can easily be deducted and a well trained and equip trader can avoid any detection by those systems monitoring the market.

The idea of simplifying regulations as mention as the reason to remove the "uptick rule", is foolish. The idea that the market can regulate itself is a dream that will never come true, history speech by itself, every problems in the capitalist world arise from rule bending It's a fact and it will never be otherwise Somebody who preach something else is probably bending it himself or largely influenced by someone who does

As for the "Naked" Short Selling Anti-Fraud Rule, it should be extended to the whole market, no exception to market makers, it is not true to that it will affect liquidity, nor it has anything to do with it It is only a way of saying I found a reason to abuse the rule If you want liquidity create a quote oriented market like on the NASDAQ exchange or on the option market Then you will have no need for exception to the rule

I'm totally against any relaxing or elimination of any present rules, I'm in favor of a more tightly regulated market enforced at the exchanges itself. Where violators are not left with time to cover their tracks, and violated don't have to juggle with all the legal issues to prove they've been defrauded