Subject: Comment on file number S7-24-99 and the regulation of short 
Author:  "GEORGE HALL" <hallg@apex.net> at Internet 
Date:    12/05/1999 7:45 PM
     
     
     
Hello, I appreciate the opportunity to comment on proposed rule changes 
regarding the OTC market. I Have not been investing in stocks very long, 
however I see shorting stocks to be a big problem for OTC:BB stocks.
    With reguard to file number S7-24-99 and the regulation of short sales
of securities, I strongly urge you to adopt regulation to eliminate short 
sales or at least control them. Borrowing stock that belongs to another person 
with
out compensation is wrong, and hurts the value of stocks.
The MM's for NASDAQ can't short sell.  Why can the MM's for OTCBB stocks be 
allowed to? 
    You allow Market makers and Off shore entities to sell things they do not
even 
own "borrowing" and in some cases that do not even exist. They simple 'rob 
Peter to pay Paul' as the saying goes.  Why should they be allowed to continue 
this activity? The MM's know the OTCBB market is not followed very closely by 
the SEC.
If you put a group of people, in any kind of business, in a position to make 
money 
any way they can, they will take it. Right now, the MM's know they can get 
away with this, and they are doing so.  The only reason it is not illegal, is 
because it is not yet a rule.  The MM's know this, so they will abuse this 
short selling procedure until they are forced to change.
    My opinion is that any type of shorting is wrong and hurts the investor
as he is unable to protect him/herself from this kind of activity. 
     
    Please exercise your options to impose honesty, fairness and a level 
playing ground on all markets. I know you are trying hard to clean up the 
OTCBB market. Someone has got to stop the MM's from playing the games 
they play. We have no one else to turn to but the SEC.  I know you people are 
understaffed 
and overworked, but this is a great proposal, long overdue.
     
Thanks George Hall