May 7, 2009
The short selling would not have become such a apparent problem if the rules in effect had been followed. If the "borrow" was not located and booked by settlement than the forced buy in rule should have taken place. I.O.U's are unexceptable. The up-tic rule didn't cause a problem before, so why not leave it alone. Re-instate the up tick rule, don't sight some lame brain research as to why it is not needed with today's smaller spreads.
Since I have your attention, I would like to explain my concerns, since I do not have Mary Schapiro's email, of the failure of the SEC to continue the temporary exemption for audits of non-public Broker/Dealers which was let expire on December 31, 2008. I realize the Hedge fund operations carried on by Bernard Madoff and his past history being Chair of the NASDAQ stock market mad him off limits to audits "because of" the exemption, but now that he is past history, all non-public Broker/Dealers no matter what size are ordered to have their audits done by PCAOB-registered accountants. Benard Madoff had a one person accountant, so does Securities Corporation of America. He was a crook and a swindler, Securities Corporation of America has a pristine record since starting in 1984. It is comprised of 2 Registered Principals. It is located in a small town in Wisconsin, with a population of approximately 11,000. Both principals are nearing retirement and were looking forward to passing on the Broker/Dealer to someone as ethical and responsible as they have been. Now that the exemption has been discontinued our audit cost well be 8 times more than before. The value because of it, will be greatly diminished. Please reconsider and reinstate the exemption.