Subject: 34-42037 Concept

Date:    09/20/2000 9:00 PM
     
     
This  is my opinion and many others who trade in the OTCBB.  Your careful 
consideration is appreciated.
     
     
1) The Brokerage practice of Naked Shorting in the OTCBB market is 
stopped immediately. The number of outstanding shares of any stock should be 
fixed at whatever number the issuing company has determined. Trading 
entities must be prevented from "adding to the trading supply of stock 
available to purchasers," and by so doing diluting the price value of 
current shareholders. 
     
     
2) Market Makers are disallowed the right to Short Sell OTCBB shares when 
the Market Makers are trading for their own accounts unless the seller 
personally owns the shares being sold. They should never have the right to 
borrow any other entities shares for this purpose under any circumstance 
whatsoever, due to their information advantage and greater flexibility 
granted to them through NASDAQ self regulation over other market 
participants such as the general public. 
     
     
3) When the Market Maker is acting it it's role as a "bona fide Market 
Maker" the Market Makers must be forced to report the real time current 
total short sales accumulation numbers in aggregate form in the real-time 
price stream, available to all through many market data vendors at 
reasonable cost. Computer Technology now allows this with the simple 
addition of a few lines of code in publicly available price feeds. The OTCBB 
already has a portion of this capability in it's ACT system, but it's not 
available to the public at a reasonable cost, nor is it available in 
real-time to the general public, only to other Market Makers. Market Makers 
must be held responsible to companies and the shareholders for failing to 
report this critical market data freely to the trading public, as a check 
and balance on their own corrupt trading practices. 
     
     
4) Churn trades between Market Makers should never be reported in the 
volume figure at all. This would halt Market Maker orchestrated and price 
stream centered "pump and dump" schemes. 
     
     
5) Violations of these suggested changes to existing law should be 
enforced with mandatory jail time, not merely monetary punishments, which 
serve as little deterrent when contrasted with the huge sums of money they 
are culling from investors day in and day out The current monetary fines 
imposed by the SEC for violations of SEC rules are relatively speaking 
"pocket change" to the corporate firms involved. They are nothing more than 
a token "slap on the wrist." 
     
Mark Martich
Barrington, RI  02806