July 9, 2008
Securities and Exchange Commission
100 F. Street, NE
Washington, DC 20549-1090
Re: Comments on Proposed Amendments to Regulation SHO
File No S7-19-07
Dear Sir:
It is most important to have opportunity to comments on the Commissions proposed amendments to Regulation SHO. I am a shareholder of CMKX and several other companies that that has appeared on the Regulation SHO threshold list day after day.
I find it quite unbelievable that less than 24 months ago the SEC did not want to even acknowledge the existance of a naked shorted share. I find it almost as unbeleivable that this issue is still open and not yet resolved to protect the average investor.
I encourage the Commission to complete the administrative steps to accomplish this change as quickly as possible. The options market maker exception has been a well known tool of manipulation and must be eliminated promptly to ensure a level playing field for public companies and shareholders.
While the elimination of the options market maker exception and the grandfather provision, these changes alone will not adequately solve the problem that results in continued naked short selling and failures-to-deliver.
I request that the Commission (1) impose in Regulation SHO a requirement of a firm location of shares to be borrowed before a short sale can be executed, and (2) enable transparency by requiring timely disclosure of the volume of failures-to-deliver shares of companies on the Regulation SHO threshold list.
The Commission should issue and implement these two critical components of effective Regulation SHO reform immediately.
Sincerely,
David M. Beck