Mr. Jonathan Katz
Subject: Petition for Commission Action to Require Short interest Reporting for all Over-the-Counter Equity Securities
Dear Mr. Katz:
I hope to find you well! I am but one small investor of many others and would like to respectfully petitions the Securities and Exchange Commission (the “Commission”) to mandate an amendment to Rule 3360 of the Rules of Fair Practice of the National Association of Securities Dealers, Inc. (the “NASD”) that would require NASD members to maintain a record of total “short” positions in all customer and proprietary firm accounts in all publicly traded equity securities and report this information to the NASD for public dissemination of the aggregate positions by security1. Under the current rule, NASD members are only required to maintain such records and make reports regarding securities included in The NASDAQ Stock Market or listed on a national securities exchange. The rule excludes OTC equity securities, thereby denying investors and the markets for these instruments the protections of transparency and regulatory oversight provided by Rule 3360. The Commission's action is urgently needed to prevent fraudulent and manipulative acts and practices, promote just and equitable principles of trade, and protect investors and the public interest.
ps, this letter is modified with cut and paste from a copy of pinksheets.com's website.