Subject: File No. S7-08-09
From: Edward Culotta
Affiliation: Former Wall Street Trader

May 5, 2009

As a former trader on Wall Street, I can tell you first hand the old uptick rule was helpful to the overall marketplace. It reduced unecessary volatility, kept traders in line, and removing it in 2007 was a mistake.

Without it, traders can "pile on" a weak stock by shorting into the weakness (just to make a quick buck)...not exactly a tactic worth protection.

Arguments against an uptick rule are baseless.

- Hedging...just wait for an uptick. It was easy to hedge before the uptick rule's removal and it will be easy after it's reinstated.

- Liquidity...we had plenty under an uptick rule (pre-2007) and we'll have plenty after its reinstatement.

Do the smart thing and reinstate an uptick rule. Take it from someone who's actually traded on Wall Street.

Furthermore, a circuit-breaker is probably a good idea, too.