Subject: File No. S7-20-08
From: Fred K Dashiell, Ph.D.
Affiliation: Visiting Scholar, UCLA

July 22, 2008

The new rule mysteriously names only 19 companies. There are many other companies whose stock has been damaged by naked short selling. They should all be protected in the same way. All short sales should require pre-borrow. All short sales should be required to settle in 3 days. Any failures to settle must be regarded as a violation, and can not be passed from one broker to another. There should be no market maker exemption.

This is a crisis in the US markets. If you don't get serious about stopping it, the whole market will crash.