Subject: File No. S7-38-11
From: Jeff Bohning

September 28, 2011

My thought is the moratorium isn't long enough and may be difficult to enforce. How will you determine if a third party is involved with an ABS underwriter to prevent them from short selling that security?

Shouldn't the move be to ensure ABS have an intrinsic value, eliminate the desire to short or eliminate short sells on specific ABSs?