Date:    12/22/1999  5:28 PM


Subject: File - S7 - 24 - 99
Dear Sec,
     
With respect to the proposed law regarding short sales of OTCBB stocks.
     
The practice of naked shorting of OTCBB stocks must be eliminated! This will 
ensure a fair and equitable market for all.
     
I am also in favour of extending existing exchange short sale rules to the 
OTC markets as well. I am strongly apposed to any elimination of the "Up 
Tick" rule which will only encourage practices such as "Piling On".
     
The Sec has been asleep at the wheel with respect to penny stocks for many 
years. The new reporting requirements for OTCBB stocks is the first positive 
step the SEC has taken in a long while. How the SEC could ever allow 
companies to publicly trade even on a non-exchange, without filing audited 
financial statements and insider reports is beyond me!
     
Now it is time for the SEC to pay close attention to the abuses by Market 
Makers who use practices such as "naked shorting" to manipulate share prices 
in their favour. And take IMMEDIATE ACTION!
     
It is clear to me that the $100 million fine levied by the SEC to the NASDAQ 
stock exchange for Market Maker infractions, has not changed a damn thing!
     
Regards,
     
Steve Fagan