Subject: Uptick comment s7-08-09

August 17, 2009

I understand that the SEC has come up with a new idea that could make changes in placing an order to sell stock short, and has asked for additional comments.

This proposal would require that short sales be made only at a price higher than the current best price being offered by would-be buyers of the stock (similar to the so-called tick-test).

I would advise that this be implemented if you wish the USA have any reasonable-term hope of maintaining credibility regarding the stock exchnages. I have some time since ceased to place money in stock exchange environments where unrestricted short-selling is allowed - in that there has been clearly no adequate regulation of related irregularities for years - and these stock exchange apologies for so-called level playing fields have made the SEC appear ineffective and of questionable purpose for existing.