March 15, 2009


Dear Mary Schapiro,

The uptick rule needs to be revamped in a 21st Century fashion.

Short Selling has a place in the the market. It has positive and negative attributes.

To make an effective tool work, its limits must considered along with the tools abilities.

Modern computer technology must be a key element in how the tool is implemented.

May I suggest a new twist on the old rule ?

Instead of an uptick, all shares being sold short must be sold on the offer. In other words, if you look at a Level II quote machine you can see Market Makers willing to buy on the bid and willing to sell on the offer.

In my suggestion, shares can only be sold on the offer. They can not be the only low offer. If they are the only low offer, they must move up to join company with the next higher offer. THEY CAN NOT HIT THE BID. No Market Orders!

When covering a Short Position, Buying back the borrowed stock, It must be at the High Bid.

Why now and why this way ? Before Level II and computer technology, this could not have been done. This way is the most effective to not distort markets or allow for manipulation. It is easy to police and will reduce volatility in the markets.

If you would like to hear more details of how this would function feel free to call me.

Douglas Fleck, President

Worldwide Financial Solutions, Inc.