Subject: File No. S7-08-09
From: James B Miller
Affiliation: Retired

August 18, 2009

Regarding short selling.

I am opposed to short selling at least on stock exchanges. I recognize that this position has zero chance of ever being fulfilled. Nonetheless, I think there are good reasons for ending short selling on stock exchanges everywhere.
1) There is no such thing as investing any more. The era of mom and pop investing in companies for the long term is gone. Stock exchanges have become giant casinos dominated by big money interests.
2) Where else can anyone sell what they do not own? In any other situation selling what you don't own will result in incarceration.
3) Regulation will never keep up with technology. Even if regulators choose to enforce agressively, they will always be one step behind.
My recommendation is to eliminate short selling on all North American stock exchanges. At least reinstate the uptick rule.
Good luck and God's blessing in your decision making and implementation.
Jim Miller