August 15, 2005
RE: File # 4-500:
Gentlemen and Ladies:
I support total transparency. The SEC, DTC and NASD continue to rationalize the veils of secrecy re who holds what short position(s). Publishing the names of the companies shorted without publishing the name(s) of the "shorter(s)" (and how much they are short) is akin to publicly naming a rape victim while withholding the names and methods of the rapist(s).
What part of R. Cromwell Coulson's following summation is unclear?
"There is a crisis facing the OTC market today in the lack of short sale position reporting and disclosure for OTC issues. This lack of transparency regarding short selling in the OTC market allows fraudulent acts to go undiscovered and manipulative short sellers to hide.
I believe regulators should fix the problem. Small issuers traded on the Pink Sheets and the OTCBB deserve the same transparency and regulatory oversight of short selling as those listed on Exchanges or NASDAQ.
Therefore, Pink Sheets has petitioned the SEC to cause the amendment of NASD Rule 3360 and require NASD broker dealers to maintain a record of total "short" positions in all customer and proprietary firm accounts in all publicly traded equity securities as well as report this information to the NASD for public dissemination of the short positions by security. The SEC's action is urgently needed to prevent fraudulent acts, expose market manipulation, promote fair principles of trade and protect investors."
SEC Staff Attorneys...how long can you continue to ignore massive electronic counterfeiting? Who among you has the balls (and committment to the small investor) to turn whistleblower? This time, the issue is not going away until you fix it. Even "little guys" like me are wising up and while I myself am no more than a pesky gnat at the moment, there is a gathering swarm of enraged gnats that just may morph into the "shorts" worst nightmare.