Subject: File No. S7-24-99.   Shorting 

Date:    06/22/2000 11:18 PM 
     
     
The SEC is facilitating an injustice upon the public by not taking action 
concerning the shorting of stocks. 
    
1. ALL short sales should be identifiable as they occur. 
    
2. The tallys of the shorted stocks position should be compiled on a daily 
basis. 
    
3. An investor should be allowed to specify that his stocks NOT be loaned 
out for shorting, regardless of whether or not they are in a cash account or
     
a margin account. Criminal penalties should be indicated if the customers 
wishes are denied. 
    
4.No stock that is not marginable should be allowed to be shorted. 
    
5. Delivery of certificates should be mandatory within 7 days if requested 
by the customer.  Criminal penalties should be indicated if they are not. 
    
6. No U.S. stock should be allowed to be bought or sold in any country that 
doesn't follow U.S. rules. 
    
7.Since the penalties for violations were enacted 60 years ago, they are not
     
in touch with present day realities.  They should all be reviewed and 
increased to be in line with the present day economics. 
    
8. While a $10,000 fine was a big deal in 1934, today it is just allowance 
money for the crooks.  All monetary fines should be increased 10 fold for 
each category. 
    
9. Since we are in the age of computers, the extra work that would be 
entailed by making the tallys of short positions known on a daily basis 
would be minimal to the people involved.  All it entails is just making a 
mark on the ticket, and the computer would do all the work. 
    
10. There is no rational reason for the SEC to continue to allow people to 
be at a disadvantage concerning their stocks.  More information is not only 
always better, it is more honest, ethical, and fair. 
    
11. Under no circumstances should an insider be allowed to EVER short their 
own stock. 
    
12.  Unless the SEC changes things they are in effect a part of the problem,
     
and that is not what they are there for.  They are there to protect the 
public at large, and not the insiders, big boys, and sharpies. 
    
13. Every stock that is traded on ANY exchange should be under ALL rules and
     
Regulations of the 1933 & 1934 SEC Acts.  There is no reason for them not to
     
be. 
    
14. Criminal penalties, i.e. jail time, should be  meted out on a more 
liberal basis than it is now, and the Gov't needs to stop coddling the 
offenders.  Stealing a few million and only going to jail for a year or two 
is not a bad deal, if you think about it. 
    
15.  The confiscatory laws should also be utilized when the offenders are 
convicted. 
    
 16. An argument could even possibly be made that all shorting for all 
stocks be discontinued.
     
The SEC and  the exchanges could just require that there be "put" options 
available for all stocks.
     
That would enable the people that think a stock is over valued to 
participate  in whatever downside they may think is there, but it would stop 
the 'bear runs", and the group efforts at driving a stocks price down.
     
17.  Whatever the SEC decides to do, I believe that the 1933 & 1934 Acts 
need to be reviewed in their entirety, and updated to be more in line with 
the present time.
     
18. The minimum '"sizes" on the stocks need to be raised.  The MM's and the 
specialists are taking advantage of the smaller sizes to 'walk a stock down" 
on 100 share lots.  The SEC and the NASD "messed up", when they changed that 
to the smaller sizes.
     
19.  The SEC needs to start enforcing Rule 10b more often, and look to the 
internet message boards because that's where the violations are occuring 
mostly now.
     
     
    
Thank you for your time, 
    
Ben   Hedges