Subject: File No. S7-08-09
From: Warren Wall, CFP
Affiliation: Wall & Company

June 15, 2009

Dear SEC,

I am an Investment Advisor Representative and would like to send you a copy of the comments made by an organization I am a member of called NAAIM. I manage over $25,000,000 of mostly retired client money that depends on "defensive" money management strategies to help protect their investments. Our having the ability to short individual ETF’s and purchase Bear Market Mutual Funds/ETF’s is critical to our "defensive" strategies. Please see our association’s formal response below. Thanks for your consideration on how changing the "short-rules" might negatively impact the “general” investing public. Thanks, W.Wall

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Warren Wall, CFP ®
Wall & CompanyTwo Town Square Blvd, Suite 310A
Asheville, NC 28803