From: Jeff Andle [jandle1@maine.rr.com]
Sent: Monday, July 23, 2001 2:35 PM
To: rule-comments@sec.gov
Subject: Fw: extension to rule 10a-1


I support your proposed changes to rule 10a-1 of the exchange act to extend
the disclosure rule to cover non exchange stocks.  I would like to offer
some additional suggestions as well.

I understand short selling serves a usefull purpose, but that it is also
used as a manipulative tool to destroy many small companies.  I am
particularly distressed that if a group of long shareholders act in concert
to protect their investment, it is considered stock manipulation, while if a
group of short sellers do this, it is considered creating market liquidity.

I feel that the rules on 5% and 10% holdings must be extended to short
positions as well as to long positions.

If a person or group control a short position exceeding 5% of the issued
stock in a company, they must be subject to Schedule 13 reporting.  All
brokers and market makers must report their short positions monthly, as is
done for listed stocks.

Even more important is this.

An individual can presently short (using a foreign trust and a Canadian
brokerage) in excess of the issued shares of a company.  I strongly urge you
to place the 10% insider and 144 restrictions on short positions exceeding
10% of the issued stock.  Such (negative) shareholders should have volume
restrictions on the quarterly change in their short position and should be
required to file in advance of additional shorting or covering.

In order to capture the off-shore portion of such shorting, any
clearinghouse or market maker transacting securities with a foreign entity
must be considered short the stock if good delivery is not made by the
proper settlement date.  This will commit these domestic entities to enforce
good delivery and preven them from being the tool of off-shore naked
shorting.