From: Hkentlewis@aol.com
Sent: Friday, May 18, 2001 10:16 AM
To: rule-comments@sec.gov
Subject: File No. S7-24-99

I would like to comment upon what I see as the situation of short selling and 
how it is reported.

1.  The first point that I would like to make is that the persons who 
actually own the shares that are loaned are not compensated for said loan 
even though the loan and subsequent sale of those shares has an adverse 
effect upon the value of that asset for the owner.  I can think of no other 
situation where someone has their property loaned out where they are not due 
some form of compensation.

2.  The current situation of reporting short interest is antiquated and 
should be addressed.  Brokerages know when short sales happen and thus the 
short sellers and large brokerages have an unfair advantage over individual 
investors.  The fact that this information is collected once per month and 
only released over a week after collection is a travesty.

With today's technology it would be a simple matter to collect and 
disseminate that information daily if not in real time.  I am able to watch 
every trade that happens.  The short sellers know if we buy.  We do not know 
if they are selling shares or selling short.  This is much less than a "level 
playing field". 

This issue is especially important in small cap stocks that have lower 
trading volumes.  We here about short attacks but, do not know about them 
until up to and at times over one month after the fact.

Thank You for your consideration.

H. Kent Lewis
Hkentlewis@aol.com
941-474-5078