March 13, 2009
Dear SEC Chariman, Mr. Dimon, Mr. Cramer (Star of CNBC Cable Television),FCC commissioners, and other ladies and gentlemen:
As Jim Cramer is probably very aware, the "Uptick Rule" gives advantage to very active "wall street" traders as opposed to "investors" or the general public. One additional element is necessary to the solution: full and immediate, ongoing disclosure by all "shorts."
The "Uptick Rule" is not enough, all short sales should be registered and made available to the general public on the web when they occur. Purchases to cover should also be made public when they occur, and short positions also made public and be updated instainiously.
Currently short positions are only available once a month and are anonymous. Short sales are not disclosed as they occur.
This change is needed to make playing field fair. Jim Cramer is probably very aware of how this change would level the playing field.
Perhaps a 1/2 of 1% charge should be made to the shortseller for each short sale to pay for this monitoring method. A minimum charge should be at least a 15 cents per share excise tax on each share sold short.
This would pay for a system that would provide full, immediate, public disclosure of short sales and short holdings, disclosing on the web who, when, how much, what price, total short holdings per seller, etc.
Mr. Cramer uses Cable Television and Broadcast Television to advance the uptick rule as "the solution" to the short sale problem. Please give some time to this more complete solution.