July 8, 2008
Dear Chairman Cox,
Thank you for the opportunity to comment on the Commissions proposed amendments to Regulation SHO. I am a shareholder of a company that has been on the Regulation SHO list for a very long time. We have been identified as "damaged" shareholders.
I praise the Commissions recent action to strengthen Regulation SHO thru the elimination of Regulation SHO's grandfather provision. I also appreciate that you have spoken about the abuses of naked short selling and the need to end this manipulative practice.
However, I am still very concerned that these abuses continue.
I would like to request that the Commission impose in Regulation SHO a requirement of a firm location of shares to be borrowed before a shore sale can be executed and requiring timely disclosure of the volume of failures to deliver shares of companies on the Regulation SHO list.
There is no question that there needs to be effective Regulation SHO reform.
Thank you for taking the time to review this letter of concern.
Barbara J Davidson