Subject: File No. S7-16-08
From: Rod Smith
Affiliation: CEO

October 13, 2008

SIRS ALL foreign brokers, dealers, corporate entities, funds, etal should not be exempted from ANY rules of disclosure or trading requirements. Exemptions have caused economic terrorism on all US exchanges in the form of naked shorting and the consequent billions of counterfeit shares as well as the destruction of thousands of companies, their products and their personnel. The SEC also must ensure that the DTCC cannot and does not lend out shares that they DO NOT HAVE ON DEPOSIT to cover shorts.