Subject: File No. S7-08-09
From: Carl A Palminteri
Affiliation: FA

May 11, 2009

Short Selling...great but only on an UPTICK, and NOT a computer generated uptick.

Naked Shorts??...Never. Must be halted immediately...If you cannot borrow AND deliver the stock by settlement you MAY NOT Short it.
No exceptions.

Mark-to-market is also BADLY in need of reform as it is being applied. Mark-to-a-conservative model makes a LOT more sense than marking down property which is NOT for sale just because a similar property may be.