From: Walter Carpus
Sent: March 17, 2006
To: rule-comments@sec.gov
Subject: File No. S7-12-06


Hello. When I bought a stock a number of years ago I did not ask for it to be delivered to me but for it to be kept in street name. Later, when there were considerable problems with what appeared to be naked short-selling associated with this stock I ask for and received my certificate. On that certificate there is a certificate number indicating that a particular number was associated with a total number of shares. It is my limited understanding that when a company issues its stock that it is turned over to a market-maker for sale. If there are 50 million shares issued, each of those shares, by certificate number could have a software program developed for it so as to keep track of exactly where each share went. For instance, I bought two million shares. I have a certificate that could have allowed that software program to show up as "issued", but not sold. If I bought the first two million shares the program would indicate that my share numbers, for accounting purposes, would be from number one to numbers two million. If I were to sell those shares, those particular numbers would be cleared for sale from the software program and be allowed to be sold to someone else. If all fifty million shares were accounted for in this regard, with each buy and sell recorded as such and controlled by that software program than that would not allow those shares, with those control numbers, to be bought again unless they were cleared as "sold" shares.

Example: I own numbers one through two million
Joe owns two million and one through two million 250 thousand
Fred owns 251 thousand through three million.
Tom owns three million one through three million two hundred thousand

If the software program indicates that shares numbered two million-one through two million 100 thousand appear to again indicate a "buy" and the program still shows that Joe still owns those shares and has not sold them, then the entity trying to buy those shares could be tracked back through their CUISIP number and be forced to provide information as to where he/she got those shares?

The minute I sell shares 1-1M, the program indicates that those shares are again available for sale. Forget all about the intended fourteen days they have to clear sales/buys. If this makes any since, or can be revamped to make SOMETHING work it will be better for our country and for our economy. Otherwise more and more people will continue to lose faith in the system and more folks, like myself, will have less and less faith in the SEC, and the DTCC.

Thank you for reading this.
Walter Carpus USN Retired