Subject: File No. 4-500
From: Ernie Rogers

November 28, 2005

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

To Whom It May Concern:

Short selling should not be allowed unless it is fully disclosed and used to maintain an orderly market in the bulletin board and the pink sheets. I have had ownership in small companies that were destroyed by naked short-selling.

It is time to stop market makers shorting small companies without regard to the investors. The SEC shouls take matters like this seriously as it is a large, dangerous, and growing problem for investors.


E. Rogers