Subject: File No. S7-08-10
From: David S Bail, Ed.D., MBA
Affiliation: Professor of Education, Walden University

September 24, 2010

Madam Commissioner,

I just found out that they're still at it. I thought credit default swaps were the worst and now regulated, but WE ARE STILL AT RISK. Look at this article on ETFs: that says: "the complexity of exchange-traded funds and their increased use as trading vehicles by hedge funds can be quietly but quickly creating serious market risk...while the SPDR SP Retail ETF has about 17 million shares outstanding, it has around 97 million shares short. Thats right, more than 500 percent of the ETF is net short."

This implies total gross ownership of XRT in the market of roughly 96 million shares, says Andrew Bogan,

Please make the economy safe from these gamblers.

I have attached a pdf on this story with links from