August 21, 2005
To: rule-comments@sec.gov
Subject: File No. 4-500


Dear Regulators:

Please amend 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.

Christian Brothers Investment Club is open to members with $100.00 initial deposit and $10.00/mo. to invest. Our club invests in startup companies which show promise. Many of these company's stock price continue to fall despite reporting news and facts which encourage investors to buy. When the stock price does rise suddenly short sellers complain and the SEC suspends trading in the stock.

We are smart enough to protect ourselves from "pump and dumps" but have no protection from short sellers. Our investment club has lost thousands of dollars due to unreported short selling. More transparency is needed and amending NASD Rule 3360 would provide it.

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 to protect small investors.

Thank you in advance for protecting those who believe and invest in the small issuers traded on the Pink Sheets and OTCBB. We believe Social Security personal accounts can not succeed without this rule change.

Keith Smith, President

Christian Brothers Investment Club