Subject: File No. S7-08-09
From: Alan S Breitman
Affiliation: Fellow, Society of Actuaries

May 8, 2009

My opinion on short selling:
1. Banning short selling was wrong.
2. Short selling should be permitted. It is a reasonable form of investment.
3. Collateral must be required.
3. Naked shorting should not be permitted. (That is gambling.)
-You shouldn't be able to sell something not in your possession. Borrowing with collateral and selling is fine.
-Nor should more shares than are in existence be permitted to be sold. That is not investing. Naked shorting permits this.
4. The uptick rule is not necessary.