September 29, 2009
INSTITUTIONAL SHORT SALES OF ANY SECURITY BY ANY INSTITUTION SHOULD BE GOVERNED BY THE VERY SAME CRITERIA AS BUYING AND SELLING BY INSTITUTIONS AND SHOULD HAVE THE SAME FORM 13F REPORTING REQUIREMENTS. FOR EXAMPLE, ANY INSTITUTION WHO SHORTS ANY AMOUNT OF STOCK MUST REPORT IT ON A(NEW)FORM 13F-S IN ACCORDANCE WITH EXISTING TIME FRAMES NOW REQUIRED FOR THE EXISTING FORM 13F. WHEN THEY COVER, THE SAME WOULD APPLY TO ANOTHER NEW FORM, FORM 13F-C. -OR- A NEW SECTION COULD BE ADDED TO THE EXISTING FORM 13F TO ACCOMMODATE INSTITUTIONAL SHORT SALES AND COVERING. THANK YOU, MARTY FAVINO