Subject: File No. 4-500

July 11, 2005

Dear Mr. Katz:

There is a crisis facing the OTC market today in the lack of short sale position reporting and disclosure for OTC issues. As things stand today, the OTC marketplace is in reality an invitation for fraud, manipulation and outright corruption against investors. The lack of transparency regarding short selling in the OTC market encourages fraudulent activities to go easily executed and undetected. The problem can be attenuated by regulation and causing the amendment of NASD Rule 3360 to require broker-dealers to maintain records of all short positions in all customer and proprietary accounts, etc., etc.(File No. 4-500)

I have personally been victimized by some "fancy footwork" by a trader and find it galling to discover that one can easily fall prey to a den of thieves. What can I do to change the situation other than to request your assistance?

Please take immediate action to alter these conditions for greater security for all. Thank you for your time.


Pat Kruger