Subject: File No. S7-19-07
From: Jay R Begun, CPA
Affiliation: AICPA, Cal. Soc. of CPA's

July 19, 2008

Reg. SHO as written is ineffectual. It fails to place the onus on the broker dealer to assure delivery. SHO must require fails to deliver to be bought in on the fail date plus one day. Using foreign exchanges to gain advantage in violation of Reg. SHO must be stopped. Exempting primary dealers makes Reg. SHO useless and ineffective. Naked short selling is already a violation under present regulations. You should strenuously enforce the current regulations against naked short selling. You should go after the Canadian and German exchanges, banks and securities firms to stop them from doing naked short selling. Small mining and business firms have been run out of business by this practice which is illegal in the first place. Action, not posturing, is what is needed.

Sincerely yours,

Jay R, Begun, CPA
931 Hartz Way, Suite 200
Danville, CA 94526