February 20, 2010
Comments Attached to Type C letter to the SEC.
I fully agree with the comments made by Jim Cramer et al to the SEC as to the Uptick Rule. A simple insertion of a code in trading platforms by programmers should solve the problem of implementing the Uptick rule. The SEC proposal of a "best bid" and a "circuit breaker", as well as the complex rules and exemptions that accompany such proposals, unnecessarily complicate the proposed rule and may render it's implementation and enforcement well nigh unworkable. The SEC's proper approach is to keep it as simple as possible and most importantly rigorously enforce it when it has been adopted.
As a long term investor, I feel that the equity markets have been seriously damaged by short selling especially in the form of "naked short selling." This has contributed to a marked change in the mentality of the markets favoring "short term trading" for instant gain instead of long term investing which is a basic necessity in developing healthy capital and equity markets.