Subject: File No. 4-500
From: James F. Walls

May 5, 2005

Dear regulators,

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.

Please amend NASD rule 3360 to fix this problem.

Thank you,

James F. Walls