Subject: File No. 4-581
From: Robert Head, FSI
Affiliation: Fellow of the Securities and Investment Institute, London.

May 5, 2009

The job of the stock markets is twofold. Firstly, they are there to provide equity and debt capital to new and quoted companies so they can grow and hopefully succeed, and secondly, to value those companies on an ongoing basis. Short selling has hugely and negatively interfered with these processes. Share prices should be valued by investors on the success or otherwise of the company and its management.

I would respectfully suggest the SEC consider a few alternative courses of action.

1. My best suggestion - short selling should be totally banned.
2. If that cannot be done, short sellers should be required to borrow stock by finding and then negotiating with a lender - not be allowed to take a negative position solely on any market "tick".
3. If short selling is allowed in any way, short sellers must become subject to rules of Full Disclosure.

The SEC failed the general investing public on this issue by removing the only barrier (the uptick rule) in 2007. It's time to put an end to this unproductive malpractice and allow the stock markets to return to their primary responsibilities, which are to finance growing companies, value all quoted companies in a fair, open and level market, and thereby support growth in the economy.