August 18, 2005
To: rule-comments@sec.gov
Subject: File No. 4-500


I have what I consider an important suggestion regarding Short Selling of pink sheet and OTCBB stocks. I have been both an investor for 35 years and was a licensed broker for 17 of those years.

Its a digrace to allow naked, "hidden" short selling of small cap companies. These are the companies, for the most part, that are struggling with financing through equity or debt and to have their stock price come under pressure with no disclosure makes it almost impossible for them to grow internally.

BE FAIR! Have them fall under the same rules as larger cap stocks whereas the shorts have to disclose their position. It is very important to these companies as well as their investors.

Also, I think it is unfair to allow accounts over $25,000 in equity to be able to buy and sell prior to trade settlements and not let those with accounts under $25,000 do so.

I'm an experienced trader and would occassionally like to trade a stock before settlement, but I cannot do so because my account is under $25,000 in cash. This is another case of discrimination against the smaller trader. What's good for the Gander ought to be good for the Goose.

Henry Good, III