Date:    12/22/1999  9:29 PM


Subject: Proposal #S7-24-99 
I am opposed to any move on the part of the SEC to allow shorting of Bulletin 
Board stocks.  There are a number of inherent problems in allowing the 
shorting of these stocks.  First of all the stocks are non-marginable and 
certainly not approved by the banking industry for hypothecation.  Reg. T of 
the banking industry would have to be rewritten if these stocks were allowed 
to be margined.  I would like to borrow money against these stocks from the 
bank, however, I believe the Banks would shudder at the thought of loaning 
money with these stocks as collateral.
     
Second, shorting of these stocks is currently allowed in two areas.  One area 
of legal shorting is market makers.  I believe the practice of shorting by 
market makers should be abolished or greatly reduced.  Currently, abusive 
short selling to the point of market manipulation is allowed and not 
monitored.  There should be severe penalties for market makers conducting 
abusive short selling.  
     
We need to step up monitoring and enforcement of existing laws to not allow 
market maker's (which often operate as wholesalers for big retail brokers) to 
manipulate bulletin board stock's price.  In satisfying their customers to 
maintain their business, they become "net short" a stock to accommodate their 
big broker's buy orders, then they wait for an opportunity to "walk the price 
down"  (price manipulation ) to buy back the stock at a profit.
     
Please stop this unfair practice.
     
Thank you.
     
Mark Tambellini
8168 Post Road
Allison Park, PA  15101