Subject: File No. 4-500
From: Peter Coolidge, Portfolio Manager
Affiliation: Deltec Asset Management

May 6, 2005

Jonathan G. Katz, Secretary,
Securities Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Via Email

Re: SEC File No. 4-500

Dear Mr. Katz:

Deltec Asset Management would like to express its support for the request for rulemaking regarding member records of "short" positions and reporting and public dissemination of aggregate positions by security.

We have found that more disclosure, rather than less, always benefits the investing community.


Peter Coolidge
Portfolio Manager
Deltec Asset Management

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