Subject: File No. S7-19-07
From: Kent Herr
Affiliation: CFA

July 17, 2008

There should be no exception to the close out rule for option market makers. The standards for delivery of shorted securities must be tightened with NO exceptions.
I would also recommend that the uptick rule for shorting be re-instated and that government officials consistently enforce these standards for listed, pink sheet and bulletin board securities. kherr 7-17-08.