From: Robert W. Hallam
Sent: March 28, 2007
To: rule-comments@sec.gov
Subject: File No. S7-12-06


After demonstrated failure for more than two years with no enforcement, writing to the SEC regarding Reg SHO is a completely wasted effort. The SEC doesn’t need further Reg SHO commentary. They’re obviously just buying time. While patsy private investors write these meaningless letters, the crooks on Wall Street are left to commit the Rape of America. Imagine you’re walking down the sidewalk and the approaching cop stops you and drags you into an alley, holding you down while the mugger takes your wallet. This is the SEC, our illustrious “cop on the corner”, in action. There are third world banana republics with more equitable law enforcement than the SEC provides.

There is no meaningful SEC enforcement, no settlement of failed trades and illegally grandfathered shares. There is no transparency. Notice that the details of the REFCO bankruptcy are shrouded in secrecy. The SEC doesn’t want the investing public to know about this massive barrel of toxic waste that threatens to collapse the market. For the exact same reason, the SEC won’t disclose the detailed, company-by-company shares that were grandfathered when Reg SHO was enacted either. Revealing any specific fails information might threaten some of the SEC’s best friends on Wall Street who are engaged in criminal stock manipulation. There are NEVER any “buy-ins” to settle the failed trades, rarely any prosecutions despite massive and widespread stock counterfeiting. Punisments are mere wrist slaps. Companies that go on the Reg SHO list can stay on the list indefinitely with absolutely no concern from the SEC. The SEC places the interests of the prime brokers ahead of their mandates at every opportunity.

No wonder thare are very few IPOs anymore. Companies are getting wise to the corruption.

The SEC repeatedly demonstrates its prime broker bias. The interests of small companies and private investors are consistently superseded by Wall Street’s widening appetite for fraud and theft. Chairman Cox and Commissioners Nazareth, Campos, Adkins and Casey show NO INTEREST in taking any meaningful action.

With this absurd re-opening of a Reg SHO comment period, I have lost all hope that any enforcement will take place. Clearly, the SEC sold out to the prime brokers a long time ago. It is time that private investors understood this fact.

Bring on the Special Prosecutor!

Sincerely, Robert W, Hallam, private investor