Subject: File No. 4-500. Request for rulemaking regarding member records of "short" positions and reporting and public dissemination of aggregate positions by security.

September 28, 2005

I strongly support the proposed rule requiring the reporting and public dissemination of short positions by security. The burden it places on brokers would not outweigh the benefits to the market which needs this information and transparency to accurately value securities. In addition, any market in the United States that is partially regulated by the SEC and has NASD participants, but still allows market manipulation to occur reflects poorly on those institutions, which are critical to the free market system. A final note is that 80% of business in the United States is conducted by “small business” and providing an equitable marketplace for those businesses is a valuable foundation to our economic system as a whole. Stability, transparency, and fair practices are paramount to providing such a marketplace.

Thank you.


Justin M. Vanderpot