Subject: File No. S7-24-08
From: Steven Moskowitz

October 2, 2008

There is not enough market transparency of short selling.

All reporting of shorted shares should be made public and made public in a timely manner.
During the trading day, it would be useful to monitor what percentage of stock transactions are short sales. Ideally, up-to-the-minute reporting of shorted sales, as a subset of total sales, should be required. Online brokerages have that information available. (Trade orders are categorized as short or long when the order is placed. )

At the end of the month, large shorted share positions should be reported in the same way that major holders must report long positions.

Market analysts say "investors have lost confidence", when in reality, "hidden" short selling is manipulating the market. More reporting and more transparency, would make the market more trustworthy.