Subject: File No. S7-12-06
From: Michael J. Kress, CPCU, MBA

January 7, 2007


I start with two painful yet incontrovertible premises:

Regulation SHO implemented now two years ago has not only NOT lessened fraud in the financial marketplace but its feckess provisions, including the grandfather clause in clear contravention of the SEC ACT of 1934, have enboldened fraud.

American financial markets are on their way to becoming the laughing stock of the world and snake pits that capital markets and investors are already starting to flee.

If you have any sense of decency or care about the future of this country, PLEASE implement a revised SHO that-- no exceptions-- requires, on pain of significant, not wrist slapping, "cost of doing business" penalties, 100% timely settlement of all failures to deliver and restores faith in American financial markets.