Subject: File No. S7-19-07
From: Chrissy Snow

September 18, 2008

The simple solution to this naked short menace is more timely reporting of the size of short interest in stocks.

To do that, stream the following data to all market participants in real time:

1. Outstanding Shares
2. Short Interest
3. Shares available to borrow (for short sales)
4. Shares not available to borrow (shares in non-margin accounts, like cash accounts, IRAs trusts).

It couldn't hurt to stream Authorized Shares at the same time.

All market participants can currently see the last trade, today's open, previous close, bid, ask, volume, high and low of the day, and more. This data is readily available. Short interest and outstanding shares are NOT readily available. Neither are shares available to borrow, except for a few broker/dealers like Interactive Brokers -- they allow their clients to query current available shares to short. Most retail brokers don't do this -- they just reject a customer order to sell short with no reason given why.

ADDITIONALLY, if all shares available to borrow were in a clearing house, then none of the backroom dealing on borrowing shares to short with would be going on. If everyone had access to the same pool to borrow shares to short from, there would be no problems.

By the way, if the SEC and FINRA required that ALL STOCKS had to stream outstanding and short interest in real time, there would probably be no market for OTCBB and Pink Sheets stocks. And that would be a GOOD THING. Those stocks are all scams anyway. Imagine being able to see the outstanding shares of a company's stock increase in real time as some scam of a company dumps shares. That would be great