Subject: File No. S7-20-08
From: John Mirabella, CFA
Affiliation: eSecLending

July 30, 2008

Under the new SEC Emergency rules pertaining to short-selling, if an investment manager has securities out on loan (through a securities lending program), and wishes to sell a security that is out on loan, is that manager required to recall a security which is out on loan prior to executing a sell order?

Under the previous rules, the investment manager could initiate the sell order first, and then contact the securities lender to do a recall.

Can you please clarify this issue, as to whether this is still the case, or must the security be recalled before placing the sell order?

Thank you.