Subject: File No. S7-08-09
From: William D Dawson
Affiliation: none

May 6, 2009

I have been an individual investor since my retirement date in 2005. This is my only source of income.

I have never been in favor of "short sales" because it is not something a residential investor can do.

In a declining market, the only ways a small investor could traditionally benefit was the "put option" or selling calls against long positions. So, it's either learn to trade options or die in a declining market.

Recently Pro Shares and Direxion have come up with etf's that a small investor can use to protect himself against the downside.

I especially use these as a "hedge" against my long investments. They are known as "inverse market etf's" and profit when the market declines. Examples are FAZ (financials), SRS (real estate), and ERY (energy).

Recently CNBC pundit Jim Cramer has been using his television show to launch a campaign to have the SEC eliminate or restrict the use of these etf's.

Evidently Mr Cramer wants ONLY his hedge fund buddies to profit from a decline in the market.

Instead he tells his audience to invest in "defensive stocks" such as Proctor Gamble so they lose less than investors in more cyclical stocks. Good grief What a strategy to advertise on a national tv station

My objective is not to "lose less" but to continue to make an income from studying the market, no matter which direction the market moves.

If these etf's are removed from my use, it will create an unlevel playing field in favor of large institutional investors.

If that happens, I will have to remove my money from my trading accounts, put it in the bank, and have to go find another job. This will be difficult since I am 61 years old and not a good long term employment prospect.

Please keep these vehicles in use for the small investor.