Subject: File No. S7-12-06
From: Maggie Butler

August 7, 2006

-Eliminate the grandfather clause

-Limit the naked shorting exemptions of the Options Market Makers and Specialists, or preferably eliminate these exemptions.

-Require a documented borrow first. No single share should be borrowed and sold more than once

-Report short sales, total short interest daily with same transparency and public reporting of total daily volume.

-Settle all trades within 3 days, buy in Failures To Deliver immediately on day 4.

-Audit the stock loan program of the DTC/DTCC and all its subsidiaries and establish oversight to assure settlement accuracy

-Prevent the hiding of over-voting of proxy shares

-Ensure DELIVERY with NO exceptions Only a UNIVERSAL DELIVERY REQUIREMENT will put a stop to delivery failures.