From: Brendan Walker [bjxwalker@hotmail.com]
Sent: Monday, December 29, 2003 1:20 PM
To: Rule-comments@sec.gov
Subject: Regulation SHO

Mr. Katz,
I am writing to express my concerns over the SEC's proposed Regulation SHO.
As a securities trader at Trillium Trading, I believe that Regulation SHO
would have a severely adverse impact on the welfare of individual investors
and traders, as well as the entire market.  If implemented, Regulation SHO
would severely hinder a trader's ability and inclination to establish short
positions by forcing him to establish the short offer at one cent from the
best bid.  As an example, if there is a stock with a ten cent spread (i.e.
.40 x .50) and a trader wishes to establish a short position, he will be
required to place an offer at the least favorble price of 41 cents.  It 
would be
just as unreasonable to establish a rule where traders were forced to
establish long positions one cent from the best offer.  In a converse
situation, the trader would be required to place a bid at 49 cents to
establish a long position.  The idea is absurd and would place undue risk on
any individual wishing to establish a position.  This proposition, along
with the other facets of proposed Regulation SHO, would completely
discourage myself, as a day trader, to ever establish short positions at
all.  Rather, I would favor establishing long positions 100% of the time.
While I am only one individual, I am sure than an inordinate amount of
individual investors and traders would take this same position.  While the
market must have a balanced level of buyers and sellers in order to operate
efficiently, this equilibrium would be completely destroyed, leaving market
makers with absolute control of market movement and individual stock prices.
  Consequently, this would severely discourage the individual trader from
trading at all.  The sum effect of which would severely diminish market
liquidity for all participants.  The market is already comprised of educated
and informed investors and traders who are fully aware of market regulations
and price movement and already accustomed to trading in this current
environment.  These propositions could only hurt the individual investor and
traders and even further discourage their participation in a market that
already favors market makers and their agendas.  I thank you in advance for
your time and consideration.

Regards,
Brendan Walker

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