Subject: File No. 4-627
From: William H James, Jr, CMC
Affiliation: Mortgage Bankers, Board Chair Residential Bancorp

May 9, 2011

present short sales procedures are dangerous and need substantial changes and or requiring the existing rules be followed

You should ONLY be able to short on an UPTICK of at least a min stated amount.
you must be able to prove the stock has been borrowed/set aside
Present rules and or lack of enforcemet of rules allow the absolute destruction of a stock by allowing unrestricted piling on