Subject: File No. S7-12-06
From: TIM E KELLEY

February 19, 2007

Regulation SHO may have been a valid attempt at correcting "naked shorting" aka fail to delivers but the grandfathering of earlier failures to deliver appears to be just the opposite.
I fail to see how the SEC has the power to grandfather out,or pardon the illegal creation of many millions of counterfeit shares.
Please do the right thing and repeal the grandfather clause and let the courts handle the fall out.