RE: SEC File No. 4-500. Request for Rulemaking Regarding Member Records of "Short" Positions and Reporting and Public Dissemination of Aggregate Positions by Security.

September 7, 2005


I am writing to voice my concern about short selling activity in Pink Sheets and OTCBB stocks, and to lend my support to a rulemaking that would require NASD members to maintain a record of total short positions in all customer and proprietary firm accounts in all publicly traded equity securities and report this information to the NASD for public dissemination of the aggregate positions by security. As an investor in OTC equity securities I believe that I should be afforded the same protections of transparency and regulatory oversight provided to investors in NASDAQ securities through Rule 3360 of the Rules of Fair Practice of the NASD.


Andrew J Befumo