Subject: File No. S7-19-07
From: Vijay Kumar

October 11, 2008

While short selling was invented so brokers could make money in commissions it fails to meet the fairness criteria. To the extent that short selling hurts the stock price, it effectively ends up hurting the lender of shares. I wonder why short selling is not deemed illegal. Should I be allowed to borrow and sell my neighbors TV? Just because the stock is not utilitarian like a TV does it in any way lessen its value to the owner? Why does my broker lend my shares without my permission? Why arent pension fund manager not sued for lending their shares and thereby hurting the pension owners? Defies imagination.

To solve the current crisis facing the nation, the SEC should take the following step immediately: DECLARE A MARKET WIDE BAN ON SHORT SELLING FOR ALL SECURITIES FOR A PERIOD OF 90 DAYS.

Please note that the market was well behaved until the day the President passed the TARP bill and from that day onwards the market has been plunging 5% a days. Reason? Because SEC had declared that the ban on short selling will end 3 days after the bill is passed. Look what happened. The market is down an unprecedented 20% for the week. SEC is responsible for the Trillions of dollars that people have lost in the stock market recently.

The announcement by SEC to lift the ban within 3 days was most irresponsible. Couldnt you have waited at least 30 days while the TARP plan was actually implemented? SECs irresponsible action is most shocking.

Please SEC folks. Please. When will you learn to do the right thing? When?

Will you PLEASE ban all shorting until the TARP plan is implemented and the credit crisis resolved and the markets stabilize?