August 10, 2010
Dear SEC Personnel:
Thank you for allowing me to address the "Short Sales" issue. As an investor, I believe that I have been hurt by short sales of stock in small companies. But, with the current reporting that is available, I do not believe this can be proven. I believe that market players, try to identify a target and manipulate the price in a variety of ways, using short positions and long positions in concert with misinformation to drive the price in ways that are not consistent with true market fundamentals of smaller companies.
I would argue for the following provisions in your comtemplated regulations:
1. Short sales and short covering transactions should be flagged and required to be displayed on all commercial stock "tickers" as such. This information should be disseminated by the exchanges in their daily recap summary data. (which also should be available for FREE at the exchange website).
2. All stock trades should be settled in 24 hours (1 day). The three day "float" in settling stock purchases, allows players in the market to short a stock heavily, then using negative stories drive down the price, and finally cover their short position (which would still be a naked short) to make large profits. Remember that this will happen to smaller companies whose price per share can more easily be manipulated. As most all trades are electronic today, this does not impose a great burden on investors.
3. Stock exchanges should not allow the information in the "book" to be sold to those who would use that information to manipulate the share price of a stock. This provides an advantage to those who would manipulate the price. They take advantage of this.
4. Market makers in a stock should not be allowed to place options contracts on the stock they make a market for. With the additional knowledge that market makers have about the stock, they can perform transactions that are designed to maximize their profits instead of providing liquidity to the market.
Thank you for your consideration of these suggestions.