Subject: File No. S7-19-07
From: Bob Smith

December 4, 2007

You have failed miserably in your mandate.

I as an American investor do not feel safe investing in the United States capital markets.
I feel that the elite enjoy one too many special money making privileges that retail investors cannot take advantage of.
Every single week a well known, global multinational, multi billion dollar corporation is choosing to voluntarily delist from the US capital markets because of your failed polices, and the way you kowtow to hedge funds when they illegal bearraid and naked short sell everything and anything that they can

1- Eliminate the OMM exception in its entirety. There is no reason for the OMM to enjoy risk free profits at the expense of equity participants.
The OMM is generating a risk free profit- that (skimmed) profit is coming out of every single retail equity shareholders pockets.
2- Force all broker dealers to mark all shares both long and short they should already be doing this- if it costs them money to implement this rule- so be it. We need more transparency not less.
3- Impose stiff monetary penalties to those that refuse to buyin their failed shares
Currently REG-SHO is toothless and worthless. There is no penalty for those that choose to fail purposefully in order to depress shareprices
4- As of today there are well over 100 companies that have exceeded t+13- The grandfather clause elimination has changed nothing- you should be embarrassed

Isnt it grand
when the NASD SEC investigates Citigroup or Morgan, and fines them a tiny token amount for breaking a massive amount of securities regulations- they never have to admit guilt to anything.

Here is an example of one where NASD fined Morgan.

executed thousands of short sales transactions without ensuring that the firm could deliver or arrange to borrow the securities by the settlement date

If they talk about Wall Street manipulation, its either bad management or pump and dump manipulation. There is no question that the P-D exists, but so does its opposite the Short and Distort. No one ever wants to talk about the S-D- in fact some deny that it even exists
Fails exist, Short-Distort schemes exist, naked shorting exists, illegal downwards manipulation exists whether you choose to accept it or not.

I have seen the chain of events that decimate stocks in the same manner time and time again.
Sequence of events happens to companies every single day

1- Volume increases dramatically- sometimes more shares than are in the float trade in a single day
2- Company goes on SHO
3-Incredibly the massive volume is all sellside- which provides gigantic downward pressure
4- The price drops precipitously
5- The media writes a bunch of negative articles about the company, but never mentions SHO, or fails, or Bear Raids
6- Every single day of the year there is a new company on SHO that goes from T+3 to T+4 and T+13 to T+14
7- When (if) some companies finally come off of the SHO list they have lost a LARGE amount of their market caps
8- When a company checks in at the SHO motel- they check out losing 50% 60% 70% percent of their value in just a short period

In short-

A company goes on REG-SHO after its been (and continues to be) destroyed, and the media has to write a story to explain (cover-up) the destruction- but it never uses the most obvious reason- illegal BEAR RAID There seems to be a moratorium on using the words- bear raid- and fails- FTD and REG-SHO in the media.

Why is it that no one in the media writes about FTD's or SHO status when they provide a negative story about a REG-SHO inhabitant?

They never talk about fails- or the fact that many more shares than the float traded- or the enormous suspicious increase in massive sellside volume.

It is so blatantly obvious that if we can put it together- I would have thought that all of these smart investigative journalists could have figured it out- at the very least one might think a journalist may question what fails are and what thier purpose might be- if for nothing else just out of sheer curiosity.

This has gone from conspiracy theory to fact.
They are so brazen that they do not even try to hide what they are doing or perhaps doing it in plain sight is the ultimate way to fool the masses.

I truly believe No stock is safe if they decide to take it down. I received an education here and it was not free.

It would seem the media and perhaps the SEC is using a dull razor instead of Occams.