Subject: File No. S7-19-07
From: Bernard Nagelvoort

July 20, 2008

Dear Chairman Cox:

When I was 12 years old (66 years ago) a friend and I made lead soldiers and got the idea that we could make lead nickels and quarters. We ended up at the office of the chief of police who gave us a stern warning about counterfeiting. We could have gone to jail for 10-20 years

The artificial creation of shares of stock through naked short sales by anyone, market makers included, is absolutely the same as counterfeiting. Should the Treasury Department allow private businesses to counterfeit money just to help them avoid financial difficulties?

It is beyond understanding that the SEC can allow any artificial creation of a company's shares. Counterfeiting Absolutely counterfeiting

Should the FHA allow the creation of shell house fronts for real estate companies to buy and sell to help stabilize the mortgage market? You would call that a stupid analogy.
But what is really stupid is the idea that counterfeiting a company's stock can possibly be made legal by SEC fiat for whatever reason

Get naked short selling out of the financial system now Not just for big banks, poor things, who got themselves into this mess with their short sighted greed, but for the sake of the integrity of the United States financial markets and capitalism.

The hedge funds will survive. They will come up with other schemes to give them an advantage over other investors because that is the way of human nature. But the SEC must at the very least not tolerate blatant acts obviously illegal by any reasonable measure

Bernard C. Nagelvoort
a long time private investor and advocate for honesty and integrity in the market place