Subject: File No. S7-19-04
From: erick s morris

May 20, 2004

What about full disclosure of share structure for these pinksheets stocks. This tends be part of the shell game scam no reporting doesnt mean share structure should be kept hidden. This allow shell companies going for long periods of time before getting shut down. Look at qbid and cmkx both started as shells and currently nobody has a clue what the share structure is except the close insiders and the dtc. The share structure reporting should be done every quarter for these companies to help prevent fraud. The growing share structure is the best indicator of fraud but if its not reported to public nobody has a clue until its to late.