Subject: File No. S7-19-07
From: Curt Hawley

August 13, 2007

Short Selling is part of the market. However, Short Selling has unfair advantages that need to be corrected, else our whole economy is at risk. Short Sales do not need to be reported like purchases. Huge blocks of short sales can be held annonymously. This is particularly dangerous when the short sales are Naked. Naked Short Sales where sellers do not have to disclose their identity are an invitation to fraud. A fraud which I have seen perpetrated time and again, and it also destoyed good companies and killed good products.
This kind of manipulation is nothing other than theft. It's legalized THEFT Finally, Short interest numbers should be reported daily, not monthly weeks after the fact. This too encourages fraud. Brokerage houses do not have to keep a clean sweep of short sales every day, so things can be manipulated and fudged for weeks. This can allow for far more shares to be shorted than legally could be allowed. But no one would know, because the reporting is so lax.

Short rules clearly need tightening, as the system is rife with fraud and abuse.