Subject: File No. 4-500
From: Suzanne Neal-Garner
Affiliation:

May 3, 2005

There is a crisis facing the OTC market today in the lack of short sale position reporting and disclosure for OTC issues. This lack of transparency regarding short selling in the OTC market allows fraudulent acts to go undiscovered and manipulative short sellers to hide.

Sincerely,

Suzanne Neal-Garner