Subject: File No. 4-500
From: Kenneth Ryan

Please consider Rulemaking Regarding Member Records of "Short" Positions and Reporting and Public Dissemination of Aggregate Positions by Security.

Please help convince the SEC not to treat the OTC secondary markets for small companies as second class citizens.

Without this rule change investors and securities regulators will be blind to any short selling activity in Pink Sheets and OTCBB stocks. The SEC needs to know that the lack of short sale information in securities is unacceptable and NASD Rule 3360 needs to be changed immediately.

NASD broker dealers should 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.

thank you,

Kenneth Ryan