Subject: Repost to prior investigation and request for follow up.
 
Date:    11/12/2000 1:40 PM
     
     
Sunflower
     
Release No. 34-42037; File No. S7-24-99       RIN 3235-AH84       Short Sales.
     
I be allowed to express some concerns. I am outraged by the behavior of the 
Market 
Makers in the OTC BB. They have demonstrated very unprofessional behavior, stole
     
money from investors, destroyed some great small companies, and displaced many 
an American worker. It is far overdue that the SEC step in and make things 
right. 
Perhaps you ask how?
     
    Act immediately, many investors have been robbed and ARE CURRENTLY being
robbed by the Market Makers. Effective immeidately require ALL Market Makers to 
make available to the SEC their long and short positions in ALL OTC BB traded 
stocks.
     
Advise the Market Makers that the SEC has the power and will randomly
examine their books for validity and verasity. Should a Market Maker be found 
to have provided misleading information (more than 5% off) STIFF FINES and 
PENALTIES will result. If a pattern is seen among most Market Makers the SEC 
will place the NASDAQ rules in place on the OTC BB Immediately.
    Then, examine the positions provided by the Market Makers and determine
for yourself whether they have abused their privledges. Do EXTREME SHORT 
positions exist? If you don't want to do it accross the board take the top 100 
stocks for the month of June (volume wise). Don't announce this until July 1st 
though.
     
This is certainly an easy way to get a very accurate gauge of how 
significant the problem is. If you indeed find a significant problem (as I 
suspect you will), then move quickly and aggressively against the Market Makers 
and place  the NASDAQ rules into effect on the OTC BB IMMEDIATELY! Should 
you do this, the  Market Makers will be required to expose their thievery and 
will 
be forced to at least give back to investor's money they have taken 
inappropriately. 
Further, If you find that they have EXTREME SHORT positions require the Market 
Maker's  to have no more than a 10% SHORT position.
 Now on to your questions....
     
1. Yes
2. Declining
3. No
4. % Change
5. No. Let the computer tell them if they can do the trade or not. 
6. Yes.
7. Not that I can think of.
8. Yes, Yes.
9. No, that's the easy way out.
10. Yes
11. Yes
12. Yes
13. Yes
14. Yes. Severe Market Maker Manipulation through EXTREME SHORTING on the
        OTC BB Market. It would seem you learned from the NYSE, AMEX, and 
        NASDAQ that the regulation was not only needed but desired. Is this not 
        also true for the OTC BB, perhaps even more so?
15. Yes. And it isn't UNUSUAL but rather BUSINESS AS USUAL by unscrupuleous
        Market Maker's who know they are not regulated and can do what 
        ever they please and answer to no one. Your job should be to make 
        the Market Maker's come clean and answer to the SEC.
16. Yes
17. Yes, but I strongly believe it has been demonstrated that the rule 10a-1
        is not only needed but strongly desired by the average investor. I truly
     
        believe that Market Maker's have a vested interest in trying to get this
     
        rule abolished so they can create a playing field like they have on the 
        OTC BB only on all exchanges, the NYSE, AMEX, and NASDAQ.
        God can only help us if the SEC allows them to do this!
18. No. It's too complex. Keep this as simple as possible. Come up with a
        simple algorithm that can easily be verified. Market Makers want very
badly
        highly complex rules because they know then there is no way for you to 
        monitor the rule. Make a rule that can easily be monitored!
19. Yes
20. Yes.
21. No
22. Yes
23. A COMPLETE HEDGE would Completely OFFSET the position held.
24. The greatest challenge facing the SEC today is the rampant FRAUD made
        against the American Investor by Market Maker's who go unregulated 
        in the OTC BB today. The solution is to randomly spot check Market
Maker's
        books and verify exactly what is going on. First understand the problem 
        and it's magnitude. Then, move quickly to put protections into place
that
        will protect the American Public. If along the way some Market Maker's 
        go out of business closely audit them to ensure they are not practicing 
        more FRAUD on the American Public.
25. No. Post a final price and make it available to all the after hour traders.
        Require them to access the site where the values are posted and to 
        use the posted values. This will result in consistency in after hour
trading.
26. Ambiguity, Uneven enforcement, and abuse of the system.
27. Greater variance in opening prices from the after hour trading locations. 
28. Little to None.
29. Little to None. However, in the OTC BB market it would be greatly desired to
        have resolution to .001 as some stocks trade for substantially less than
1/16th.
        Also, I might add, it is outrageous to see a stock which the previous
day had
        a 1 Million share trade followed by the next day when the market makers 
        have a bid / ask of .03 x .045!!! The spread is 50% of the value of the
stock.
        Just another example of how Market Maker's will try to drive a stock
price
        downward.
30. Depends. If the stock is trading for .01 then yes! Some OTC BB stocks trade
        SubPenny. It truly depends on one's perspective and the price of the
stock.
31. No. Do not eliminate rule 10a-1. Only the Market Maker's want this rule
        abolished and perhaps some institutions. The small investor loves this
rule.
32. Yes
33. No
34. As previously stated, the biggest challenge facing the SEC today is cleaning
        up all the FRAUD that is going on in the unregulated trading arena- The 
        OTC BB! The steps taken by the SEC to require listed companies to meet 
        certain standards and provide financial information has helped
tremendously
        in cleaning up some of the OTC BB problems. The WAMX bust was
noteworthy!
        But..... Much WORK remains in ensuring that the Market Makers are
treating
        the American Public fairly. One certainly must ask why are the OTC BB
and
        the pinks the only non-10a-1 regulated trading environments in the USA? 
        In my opinion, the rule 10a-1 should apply to ALL USA trading
environments.
        Protection for the American Investor should apply on all platforms not
just
        the BIG BOARDS!
35. Yes. See my position in Question 34.
36. IMMEDIATELY! This should have been done 2 years ago (I know this wasn't the
        answer you were looking for but it is my OPINION!). and YES, begin with 
        the NASD Model and study / learn. Ask for opinions on modifications and 
        see what shares out...
37. Yes
38. Yes. Again, the biggest problem you have is the OTC BB and Market Makers. 
39. Yes
40. No. No.
41. YES!!! AND IT IS VERY BADLY NEEDED! MARKET MAKER'S HAVE ABUSED THE
        AMERICAN PUBLIC AND DONE SO OUTRAGEOUSLY WHILE THE SEC HAS 
        STOOD ON THE SIDELINES AND WATCHED. THE TIME FOR THE SEC TO ACT 
        HAS CAME AND WENT SEVERAL TIMES. DO SOMETHING! STAND UP FOR THE
        AMERICAN PUBLIC! In fairness I must admit some of the changes of late 
        have helped and have been good. Most notably the rule that requires 
        certain minimum standards by companies on the OTC BB. Now it is time 
        to make the OTC BB like the NASDAQ/NYSE/AMEX so ALL AMERICAN 
        Investors are protected!
42. Yes. Yes.
43. Yes.
44. Yes. Yes.
45. No. Until you can define how you can adequately do this my answer is NO! 
46. Don't rescind rule 10a-1. Require Market Maker's to FULLY DISCLOSE their
        long and short positions on ALL Markets! Look where the CANCER is
growing-
        It is in the OTC BB where no regulation exists.
47. Yes but the rule is still needed.
48. Yes. Here again, the OTC BB Market Maker's are your greatest problem today! 
49. Don't rescind. Don't know...
50. Yes. Put NASD rules into place for the OTC BB IMMEDIATELY to PROTECT TODAY's
        Investor. Then, take your time and study but do something NOW to PROTECT
     
        the American Investor TODAY! The OTC BB Market Maker's have made fools
of
        not only the SEC but also the American Investing Public. It is past time
for the
        SEC to even the playing field and put rule 10a-1 in effect on ALL
MARKETS!
51. Yes
52. Yes
53. Yes.
     
I have spent more than 2 hours of my time carefully considering your questions 
and expressing my opinions. Please, Please, Please, PLEASE.....
     
 DO SOMETHING TO CLEAN UP THE MARKET MAKER MANIPULATION ON THE OTC BB!
     
Sincerely and thanks for letting me voice my frustrations about a system gone 
amuck...
     
Paul Louis Goding
14030 Biscayne Blvd. #904
N. Miami, FL:  33181