Date:    06/26/2000  6:34 AM

Subject: Rule changes effecting short sales

Gentlemen:
     
The current practice of shorting OTCBB stocks by market makers acts, in 
many cases, contrary to the purpose of 'Making a Market.' The brokerage 
house (market maker) effectively creates phantom or counterfeit shares 
through shorting. This artifically dilutes the market and effects the 
price in a negative manner. Many companies have suffered the effects of 
this practice even in light of positive financial data and positive 
business dealings.
     
The individual investor and the companies are both effected in a very 
negative manner by this form of manipulation. In the past you (SEC) have 
frequently uncovered massive abuses of the current practice of naked 
shorting OTCBB stocks. The brokerages have always settled by paying 
large fines and then going right back to business as usual. The 
individual investor has been taken advantage of over and over. The only 
positive method for dealing with this abuse of the individual investor 
is to require that the short positions be reported and exercise the 
tight oversight.
     
Thank you for the opportunity to respond to this proposal.
     
Larry D. Tindle