Peter Murgolo
Heartland Securities
110 Fieldcrest Ave.
Raritan Center 1
7th Floor
Edison, NJ 08818

Mr. Jonathan G. Katz, Secretary
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549-0609

Dear Secretary Katz:

As a proprietar trader and a registered representive at Trillium Trading LLC, I am concerned about the proosed rule SEC Rules 3-b, 10a-1 and 10-2. The change to Regulation SHO that requires a short sale can only be effected at least on cent above the best bid can and will be detrimental to my abiliity to get shor a stock. This rule will not only hurt my trading, it willcause the market to have an untrue price. Making money on the short side will now become very difficult amd will have effect on traders through out Wall Street. This rule change will have to much of a negitive effect and should not be implemented. A changeis unnecessary.

My feelings are that current rule should stay in place and allow traders to excel in what they do best. Traders over the years have come acostom to getting short on an up arrow and have made many good trades that have benefited themselves and the market as a whole. A change in the short sale rule would created many seasoned traders to become hesitant to get a short a stock because it would become very difficult to short on a cent above the best bid. In turn, this will cause the market to have a false appearence, since there will much less short selling.The financial markets strives on giving traders as whole, from instutional traders to private investors the best price, and this rule will make it hard for the market to show the best price. I believe that the current rule benefits traders as a whole and benefits the market. It gives the market and stocks the truest price. A change will only cause problems.

The only who will benefit in this rule change is large institutional firms, who would be able to short a stock and gain an advantage against smaller investors. There should be a level playing ground, where all traders have the same opportunities, so that a fair market is created. A fair market can only be created if every trader follows the same rules and has the same opportunity to buy or sell a stock.

I feel passionate about trading and find it to be the greatest job, but a rule change like this will make it hard for me and many other traders to stay sucessful and in turn stay passionate about trading. This rule change will forever hinder my trading ability and my goals to be a very successful trader. A change is unnecessary.


Peter Murgolo
Trillium Trading