July 19, 2006
To Whom It May Concern:
After years of reading about the fairness of the market, only to be blind-sided by the unfair language in Regulation SHO, I question what good it will really do to submit comments concerning proposed changes.
The "grandfathering" clause included in Regulation SHO is grossly unfair to ordinary shareholders. I am still waiting for the SEC to explain what was so critical to the best interest of the financial markets that the grandfathering provision was seen as necessary. Whoever it was at the SEC that deemed this to be so critical should explain to the ordinary shareholders just how bad the problem appeared to be at the time. It is my belief that unless the problem was major, there would be no need to include such a provision.
Maybe it's because of my lack of knowledge regarding the inner workings of Wall Street but, the whole subject of locating stock to borrow seems like a fantasy. Even if there is reasonable certainty that a stock can be borrowed at any given time has no bearing on whether that stock can be borrowed some time in the future. To me it seems to be an unfair advantage that isn't available to the ordinary investor.
Who wants to invest in a market with such unfair rules?
J. Bennett