Subject: File No. S7-20-08
From: J Keith Stucker
Affiliation: SVP Financial Consultant Portfolio Manager

September 10, 2008

How many more financial institutions will go under before you put into place the Naked Short Rules and re institute the uptick rule that was wrongly removed July 2007?

Since the expiration of the emergency order we have now seen the aggressive shorting return and the demise of FNM FRE and soon LEH then?

In a period when our financial institutions are in dire need of raising capital, the aggressive shorting robs them of their capital sources. It is pure and simple a theft of capital. The shorts drive down the prices to levels where these companies can no longer raise capital effectively, and are forced to sell assets or break up. Then the ultimate run on the banks occur. Bear Raids are alive and well because of the removal of the uptick rule and the naked shorting. Please Please Please stop the madness

J Keith Stucker
RBC Wealth Management