July 16, 2008
Ladies and Gentlemen:
As drafted and enforced, regulation SHO is systematically ignored,
circumvented and abused. The operative rule for ALL securities should be
the one recently imposed with respect to the shares of Fannie Mae, Freddie
Mac and the primary dealers: preborrow the stock -- no exceptions. Rules
changes and the absence of SEC market enforcement in recent years has
created a market characterized by unprecedented volatility and predatory
practices not seen since the 1920s. It's time to clean it up.
Sincerely,
H.W. Shaeffer
H. W. Shaeffer, Esq.