Subject: S7-19-07

July 9, 2008


The Grandfather clause in Reg SHO is patently unfair to all but those who game the system; for them itís green light to keep ill-gotten lucre and continue the charade. All we small investors request is full transparency and an even field. A good start would be to open the books of the DTCC & lose the skewed stock borrow program that facilitates counterfeiting of market securities. Call counterfeiting what you will; failures to deliver, naked shorts, phantom shares, desk trades, ex-clearing, settlement failures, whatever. Counterfeiting by any other name is counterfeiting. Why another comment period is needed is beyond me. What part of the truth does the SEC fail to understand?

Dennis Smith
San Diego