Subject: File No. 4-500
From: Chester Billingsley, President Main Street AC, Inc.
Affiliation:

May 3, 2005

SEC ---- In drafting rules with regard to short sale reporting the SEC should focus on the areas of greatest harm and abuse -- which are the OTCBB and Pink Sheet companies.

In larger NASDAQ and NYSE companies, short sales can present a reasonable investment alternative when a investor feels a stock is overvalued. Reporting this is proper and gives transparency to the market.

In smaller OTCBB and Pink Sheet companies, a broker can find ways to short the stock in excess of allowed (even though the rules say he may not) in part because there is little reporting required or compliance with those rules. As a result, smaller companies and their investors, hoping to get some public financing or liquidity, are not able to because the market liquidity has been directed into the pockets of the shorting brokers.

In relative percentage terms, the shorts and naked shorts do far more damage to the smaller companies than they do to the bigger ones.

Requiring reporting of larger company shorts and not that of smaller companies, is like requiring bullies to report when they pick on football players, but giving them a pass when they pick on the geeks.

The illegal practices are so common and egregious in the Pink Sheet arena that the best solution would be ban short selling in those stocks. Certainly, tighten it more in this arena than in the larger company stocks, or at least make it equal.

Regards,

Chester Billingsley
President
Main Street AC, Inc.