Subject: File No. S7-31-08
From: Steven Moskowit

October 21, 2008

1)There is not enough market transparency of short selling.

All reporting of shorted shares should be made public and made public in a timely manner.
During the trading day, it would be useful to monitor what percentage of stock transactions are short sales. Ideally, up-to-the-minute reporting of shorted sales, as a subset of total sales, should be required. Online brokerages have that information available. (Trade orders are categorized as short or long when the order is placed. )

At the end of the month, large shorted share positions should be reported in the same way that major holders must report long positions.

2) Every stockholder, whether an institutional or individual investor, should be able to make their shares unavailable to short sellers. There should be daily tabulations of how many shares of each security are available for short selling. Not only should naked shorting be forbidden, statistics should be public so the market can keep tabs on excessive shorting i.e. beyond the permitted number of shares.

More reporting and more transparency, would make the market more trustworthy.