Subject: File No.S7-24-99 SHORT SALES
Author:  "Peter Chepucavage" 
Date:    06/13/2000 8:37 AM
     
     
The Commission should clarify when the tick test applies overseas The 
test should not apply after hours for legitimate trades i.e. those in 
which the seller is truly at risk. A similar rationale should apply for 
those getting long overnight. The tick test makes no sense for trades 
done at midnight over the counter in a foreign country.