Subject: File No. S7-08-09
From: Tom Firrone

May 5, 2009

I am not in favor of a ban on short selling (SS). However, I am very much aware of how SS can distort a market. Perhaps limiting the magnatude of SS should be considered (I.E., 1,000 shares per brokerage account).

I am a small investor and have a hard time understanding how a ban on short selling by all but the big traders will have any effect on the market (statistically).

I recall that after the "crash" of 1987, circuit breakers were installed (a 3 tier system) on the market trading. I don't know if these are still in effect. I don't recall seeing them imposed in the past few years. I thought those were excellent circuit breakers, especially if the objective was to let cooler heads prevail in times of radical movement (up as well as down). Those (post 1987) circuit breakers may need to be reexamined for validity.

Tom Firrone