Subject: File No. 4-500
From: N. J. Panicaro, EVP & COO/Treasurer
Affiliation: Old Florida Bank

May 3, 2005

We are writing this email to advise you of our support of SEC File No. 4-500, Request for rulemaking regarding member records of "short" positions and reporting and public dissemination of aggregate positions by security. We agree that action on this issue is urgently needed to prevent fraudulent acts, expose market manipulation, promote fair principles of trade and protect investors. This is a critical part of the securities market that needs improvement to ensure that companies are traded in transparent, efficient and well regulated OTC markets. Thus, we are asking that you make this important rule change happen.

Thank you, in advance, for your time and consideration on this very important issue.

N. J. Panicaro,
EVP & COO/Treasurer
Old Florida Bank


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