April 16, 2009
Dear SEC
What you are proposing is a down tick rule This is useless
We need an up tick rule - That is shorts can not be executed until a stock rises 20% in one day.
There is no transparency in shorting.
You need to require all shorts be reported like long positions. You need to require documented pre- borrowing and their owners must be compensated.
This must be controlled by an independent organization - The SEC - banks, Brokerage houses rating agencies- have shown they can not be trusted.
Any stock on the sho reg list means the the rules are not followed- shares were sold but not bought back.
The SEC is not doing its job. And the present owners of those stocks need to be compensated by those who shorted the shares.
Since all shorting of stocks is not public or open it is clear - all shorting is essentially naked shorting. How can any one have confidence in a system like this?