Subject: File No. S7-08-09
From: John Neff
Affiliation: President of a management consulting firm specializing in small cap companies

May 6, 2009

I am for reimposing rules regarding short sales. I have seen numerous client's stock be driven down by unscrupulous brokers by short selling their stock knowing that they can buy it at a fraction of the cost they sold it for to cover delivery and pocket the spread. This ability to do this either as a naked short or having other shares of customers at their brokerage house which they can borrow from, thwarts the whole concept of a free trading market. It can easily ruin a small companies stock value in a matter of days.

We have advised our clients against keeping shares in non certificate form at a number brokers/dealers that play this game, which I refer to as "a license to steal" and has nothing to do with keeping an orderly market.