From: Donald L. Smith
Sent: September 12, 2005
Subject: File No. 4-500

Dear Mr. Katz,

Please take action that would require NASD members to maintain a record of total short positions in all accounts for all publicly traded equity securities and report this information to the NASD for public dissemination. Currently, this is only done for securities traded on the NASDAQ or a national securities exchange.

I am sure that much of the stock manipulation currently taking place on OTC equity securities would evaporate. Specifically, naked short selling.

Thank you in advance,

Donald L. Smith
20 West Union Street
Goffstown, NH 03045