Subject: File No. S7-19-07
From: Carol C McCrory
Affiliation: Former Visiting Assoc. Professor of Legal Skills, Stetson University College of Law

July 30, 2008


It is a shame the Commission has continued to fail to enforce the existing regulations against NAKED SHORT SELLING, a practice harmful not only to individual investors, but to our economy as well.

I support elimination of the Market Makers exemption.

I support amendment to rule 203(b)(3)(iii) of Regulation SHO - completely eliminating the close out exemption for option market makers as proposed (not alternative 1 or 2) .

I support amendment to rule 200(g)(1)which would require a "locate" on short sales securities and proper marking of sales as "long" or "short".

I also support amendment to rule 200(g)(1) proposed in the second round in release 34-56213 File No. S7-19-07 because equity investors are being harmed from mismarked sales as "long" when they are NAKED short which counterfeits shares--an illegal activity.

Finally, I support the reinstatement of the "uptick" rule.

In the event of failure to amend rule 200 (g) (1), please make and release a cost analysis incurred by equity investors.

The SEC must do a cost analysis incurred by equity securities investors if you do not eliminate the market maker exemption, as your new data clearly shows the "fails" are being produced by invoking that exemption which, in turns, harms equity investors.