Subject: File No. S7-08-08
From: Sigrid G
Affiliation: mother

March 21, 2008

While hunting through SEC documentation for some shred of evidence that there are in fact CLOSING requirements for stocks that have been on the Threshold list for hundreds of days, I have just read the 2004 "Final Report" on Short Sales.

Looking at the details of 203 (b) which references 11830 etc, I noticed more than one reference to "calculations" and "programming" as reasons or factors for not being able to really assure veracity of trades. No wonder the SEC doesn't know how to reconcile failed deliveries. What would you think if when you took your money to the bank, they just threw it in a big bucket with everyone else's then started taking money out again when any old check came in. THen when there was more checks outstanding than money the bank said "well, it's not our fault all we have is that big bucket and we don't know what is whose in there". That's like my 15 year old's style of excuse.

I am 100% confident that programming talent exists out there that could analyze, design then implement unambiguous logic at the DTCC which would assure that transactions could be reconciled according to the "paper-based certificate" model that was intended way back when (just faster). Will it take time? Yes of course it will. Lots of testing and inconvenience too.

But leaning on an excuse like "cost prohibitive" programming requirements or "our system doesn't calculate it like that" is like a police officer standing there with a bow and arrow saying "I can't stop the bank robbers with this". Don't you have enough proof yet that the very rules you and the DTCC are implementing are DEstructive rather than CONstructive.

The trend of failing small companies was like a canary in a coal-mine however the recent failure of big multi-billion dollar entities in the financial sector is more like the total collapse of the mine itself.

I feel 100% confident that the fines pending out there that are never collected for illegal naked shorting (which is set up specifically to be undectable) would pay for the entire development project and then some. You have no excuse with today's technology to hide behind lame 8.5 X 11 documents that ambiguously describe how these proceedings, which CAN BE expressed in PURELY MATHEMATICAL terms, should work in a way that veils and protects criminal opportunities of gigantic proportions.

There are more exceptions and dancing around the closure rule than wording of the rule itself. Start with a paper model in small proportions. Then scale it up and speed it up. Honestly, what is your system implemented in, COBOL? Or maybe Basic? a billion linked Excel docs with VBA (you'll never get to 2007)? It's the new millenium now and we have better alternatives for distributed processing.

If you need a good project manager to get all the liars in a room and work out the requirements then design and implement a system, give me two years,a team of about 15 of your best developers (not COBOL) and just enough authority to make all stakeholders own it and be accountable for results, and I'll get it done. You have my email address.