RE: S7-24-99

Dear Mr. Pitt,

As an individual investor who attempts to do extensive DD before buying or selling any security, I implore you to extend the short sale regulations to the OTC BB market.

The Nasdaq OTC provides the best risk / reward opportunity for many small investors like myself. We understand the risks involved with investing in companies with potentially great ideas, but lack the inside connections necessary to acquire first class financing. We understand the risk involved with buying into an idea that must be funded with convertible debentures. We spend hours researching and debating the potential success, we call CEOs for information, we track down rumors, we attempt to temper "pumpers" and we try to refute the "bashers." We definitely understand the risks. What we NEED is help in reaping our rewards when we are right.

OTC market makers MUST be required to report their short positions. How can there be a level playing field when market makers are allowed to short securities, knowing that they will never have to cover their position? Short selling is a necessary part of liquid market. Knowing that short position is part of any investors' DD in all of the listed securities. Help us to make it part of the standard DD for any OTC security.

Mr. Pitt, on behalf of myself and many, many other small investors who have not responded to this concept release, I BEG you to extend short sale regulations to the OTC BB market as soon as humanly possible. Help give us the free trading market that is necessary to maintain faith and trust in our leaders. Stand up for the individual investors and their money rather than the manipulators, and insiders. While I would dearly love to provide you with detailed examples of the manipulative and corrupt behavior that we both know exists, there is currently no way for me to gather that information.

However, I would welcome the opportunity to discuss this further with you or any member of your staff at any time.


John Prentice

DATE:September 5, 2001
TO: Rule-Comments@Sec.Gov
FROM: John Prentice
6201 Center Street
Mentor, OH 44060