Subject: Release S7-24-99

Date:    11/28/99 1:51 PM
     
     
I am an individual investor and trade through a retail brokerage firm. 
In my opinion the SEC should move with all deliberate speed to extend 
the type of protection afforded by the NASD Rule 3350 applicable to 
short sale of NMS listed securities to individual investors and others 
who invest and trade in stocks through the NASD's OTCBB, and 
Nasdaq:SmallCap, and the Pink Sheets.
     
Adoption of such a regulation to regulate short selling of securities 
traded in OTC markets would accomplish objectives which would provide 
reasonable protection to individual investors and the companies whose 
securities trade on OTC markets. In my opinion, adoption of a regulation 
applicable to all OTC securities trading which is similar to NASD Rule 
3350 would:
a)  allow relatively unrestricted short selling in an advancing market;
     
b)  prevent short selling at successively lower prices, thus eliminating 
short selling as a tool for driving the market down; and
     
c)  prevent short sellers from accelerating a declining market by 
exhausting all remaining bids at one price level, causing successively 
lower prices to be established by long sellers.
     
d)  prevent short selling that could manipulate or depress the market 
for a security, irrespective of the intention of the short seller.
     
Lastly, the SEC should adopt a rule applicable to all OTC securities 
trading which requires NASD member firms and market makers to publicly 
report aggregate short positions in all OTC securities.
     
Sincerely,
Thomas L. Austin