From: George Magnus
Sent: Friday, April 06, 2001 2:00 AM
Subject: File no.s7-24-99



--- George Magnus

In reference to question 9: Is it appropriate or preferable to base short
sale regulation on general market movement rather than the price of
individual securities?

The answer is yes.A 20% drop in the market is considered a bear market.
Short selling aggravates this situation. No short selling should be allowed
in any market after it drops 20% or more.

In reference to questio 16: Should short selling be prohibeted for a period
preceding a siginificant corporate or market event. The answer ie yes.