Subject: File No. S7-12-06
From: Charles E McNeely

January 17, 2007

Dear SEC members

I am asking that you abolish the grandfather clause of Regulation SHO inacted in Jan 05. Naked Shorting when done to manipulate the markets( which this was) is ILLEGAL. This Grandfathering of these FTD's is ILLEGAL and thus the entities that are illegally short have a responsibility to cover their position within the guidelines of REG SHO and in a timely manner.

When I recieved margin calls in 2000 I followed the rules and covered my margin responsibility within the 3 day guideline. Nobody gave me extra time to the tune of months and in this case 2 YEARS to cover my margin position. I knew the rules when I made my investment decision and so does these Naked SHORTERS.

All investors , Individual or Institutional should be playing by the same set of rules and on a level playing field. Regulation SHO must be inforced and the grandfathering clause must be abolished

Charles McNeely