Subject: File No. S7-08-09
From: Frank C McMorrow
Affiliation: MBA

August 19, 2009

After looking at your proposal I am at a loss to see how you are preventing "naked shorting". Legal shorting should be allowed but a connection needs to be installed that forces the "borrower" to settle in 3 days. This should be simple enough. I do not understand why you have such a complex proposal. Counterfeiting of stock is illegal and
undermines the system and the wealth of all Americans.

By not properly addressing the issue, you are being complicit in the fraud. The DTC should have an automatic debit of an investors account after three days if delivery is not complete. A failure beyond this should be reported to the SEC for disciplinary action. What is the big problem here.


Frank McMorrow