From: ddrosd [ddrosd@adelphia.net]
Sent: Wednesday, November 19, 2003 1:54 PM
To: rule-comments@sec.gov
Subject: File No. S7-23-03


Thank you for this opportunity to share my comments in regard to SHO.

Many others have already addressed specific issues as it applies to
proposed changes and have done so quite well. Therefore, I will limit 
my comment as it addresses the issue of naked shorting, in my opinion.

Enforcement is key to the markets today. Naked shorting would not be an
issue if "strict enforcement" for all settlements would be mandated 
across the board. These regulations already exist, but needs to  be 
enforced for brokers, market makers and regulatory bodies of 
the SEC, DTC, etc. These bodies need to be part of the solution rather
than a large part of the problem as broadcast by the media.

Rules, regulations and mission statements are only for those wanting to
obey them. Therefore, strict enforcement and commitment is necessary for full
compliance. Keeping that in mind, selling an unlimited amount of shares in any
equity without a final accounting is license to steal. That is the quandary 
the market finds itself in today with regard to naked shorting.

There are thieves among us who are doing more damage to this country and
its investing citizens than any foreign terrorist group could inflict. These
"financial terrorists" are motivated not only by their own greed but by the 
secure knowledge that accountability will not be an issue. In this respect, 
the SEC is blatantly responsible since it has known about the concerns of 
the American investor for the last 5-6 years via letters of complaint.

If it were not for the efforts and uncompromising stance of AGNY Eliot
Spitzer, I seriously doubt that any of this criminal activity would have 
been brought to light. If one man can make such a difference, then what 
could the SEC be capable of "actually doing" if they were as determined
to right wrongs as Mr. Spitzer ?

Further, when billions, yes billions, of shares are traded in a single
day, in one equity, without "any" price per share movement, there's a big 
problem there. What's that problem ? The lack of strict enforcement in 
regard to all settlement timelines, as already set forth in existing
regulations. Additional measures should be taken to further block all
loopholes as it refers to borrowing/hypothecating certificate backed 
shares from investors' accounts, be it cash or margin. And, make all 
changes retroactive to right the wrongs of past crimes.

Please remember, that while you good people take these 60 days to gather
comments, and additional time to put forth new guidelines, the investing 
public is still being financially brutalized without mercy.

Best Regards,
David Drosd