From: Kristopher Goldhair [kgoldhair@hotmail.com]
Sent: Monday, January 05, 2004 10:38 AM
To: Rule-comments@sec.gov
Subject: Regulation SHO

Securities and Exchange Commmision

450 Fifth Street, NW

Washington, DC 20549-0609



RE: File No. S7-23-03 



Dear Mr. Katz:

Please find enclosed my comments opposing the proposed Regulation SHO. I am 
an equity trader with over 4 years experience and an Economics Degree from 
Columbia University. The proposed regulations, namely the statute allowing 
short sales to be effected only one cent above the bid, would be a severe 
hindrance to a fair and orderly marketplace. However, the pilot program to 
study the effects of relatively unrestricted short selling on liquid 
securities is a fine idea that deserves to be studied.

Permitting short sales only above the bid would create unnatural equity 
pricing. Stocks would not be able to flow to their correct levels due to 
market makers and ECN's keeping irrelevant prices. The illiquidity from 
these static quotes would also hurt the marketplace for obvious reasons. For 
example: if an Instinet in YHOO were able to hold the bid unmolested for hours 
while the market was collapsing, inefficent and unfair pricing would result.

The pilot program allows for true capitalism in the marketplace. It would 
give stocks the transparency and liquidity the United States securites market 
deserves. I am in favor of testing this regulation.

Investors and Traders depend on the SEC to maintain an equitable, transparent 
and most of all free stock market. I have clearly stressed my position on the 
proposed regulations and hope the SEC will consider my opinion. My elite 
education and significant professional experience lend credibility to these 
ideas. Thank you for your time.



Sincerely,

Kristopher Goldhair



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