From: Mark Smith
Sent: September 12, 2005
To: rule-comments@sec.gov
Subject: File No. 4-500


Dear Sirs

Re: Request for Rulemaking Regarding Member Records of "Short" Positions and Reporting and Public Dissemination of Aggregate Positions by Security.

We need to make the OTC market transparent and fairly regulated. Short selling is the bane of small public companies who are often spending significant time and resources to increase the value of their stock for legitimate business purposes.

Regards,

Mark Smith
Managing Partner
Securities Compliance