July 21, 2005
Jonathan G. Katz
Secretary, Securities Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Barbara Z. Sweeney
Senior Vice President and Corporate Secretary, NASD
1735 K Street, NW
Washington DC 20006-1500;
Dear Mr. Katz and Ms. Sweeney:
As a Chairman and President of a OTC traded company, PITBOSS Entertainment (OTCBB:PBSS) as a shareholder of Pinksheet listed companies and as a American concerned with the integrity of the US public securities marketplace, please accept this electronic message in support of an amendment to the rules affecting short position reporting by NASD member firms.
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, I am pledging my support to the petition sent 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.
Respectfully submitted,
John D. Jarvis Jr.
Chairman / CEO
PITBOSS Entertainment Inc.,