Subject: S7-24-99 Author: "John A. Bard" at Internet Date: 12/05/1999 12:39 PM Rule: S7-24-99 Author: John A. Bard, Mount Vernon, Wa jab@fidalgo.net Sirs, Long needed reform such as this has my unqualified support. Reporting by Market Makers should be at the minimum weekly. Market manipulation by short sellers seriously impedes business' ability to access capital, and for investors to make intelligent decisions based on real market place factors. The manipulators reap large profits at he expense of business and investors and discourage honest investors from participating in the process. My opinion is accurately articulated by a previous respondent, who I quote below.. In my opinion the SEC should move with all deliberate speed to extend the type of protection afforded by the NASD Rule 3350 applicable to short sale of NMS listed securities to individual investors and others who invest and trade in stocks through the NASD's OTCBB, and Nasdaq:SmallCap, and the Pink Sheets. Adoption of such a regulation to regulate short selling of securities traded in OTC markets would accomplish objectives which would provide reasonable protection to individual investors and the companies whose securities trade on OTC markets. In my opinion, adoption of a regulation applicable to all OTC securities trading which is similar to NASD Rule 3350 would: a) allow relatively unrestricted short selling in an advancing market; b) prevent short selling at successively lower prices, thus eliminating short selling as a tool for driving the market down; and c) prevent short sellers from accelerating a declining market by exhausting all remaining bids at one price level, causing successively lower prices to be established by long sellers. d) prevent short selling that could manipulate or depress the market for a security, irrespective of the intention of the short seller. Lastly, the SEC should adopt a rule applicable to all OTC securities trading which requires NASD member firms and market makers to publicly report aggregate short positions in all OTC securities. Sincerely, John A. Bard