Subject: SEC Pink Sheet Rule Changes

November 4, 2005


I am writing to strongly urge you to approve the amendment of 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. The SEC's action is urgently needed to prevent fraudulent acts, expose market manipulation, promote fair principles of trade and protect investors.

I cannot begin to explain to you all the reasons I have personally experienced in the last 6 months of trying to work just ONE pink-sheet stock.

Don’t wait for a national scandal to occur. Again, those of us working in the “Pink Sheet” realm would greatly appreciate your full consideration in this matter. In this day of electronic communications and storage, there should not be any significant issues in adopting this rule change.


Mike Harper