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Draft of Comment Letter For SEC Reg SHO Request For Comments

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Posted by:   bobo 8/16/2006 4:37 PM

Here is a draft of a comment letter that can be easily downloaded and modified to suit your needs.

The two additional suggestions are obvious modifications that Reg SHO should contain. Feel free to add your own additional thoughts.

As an FYI, NCANS is working on a draft of a comprehensive comment letter/proposal, and will be seeking to get signatures for it from any and all NCANS members, as well as the readers of this blog. Once the document is completed, I'll set up a fax system or some other mechanism for users to sign the letter, and then submit it to the SEC before the deadline.

That letter is quite detailed and technical in terms of the changes that need to be made. This one is a more general, short and to the point document.

Feel free to download it, change it as you see fit, and send it off.
Copyright ©2006 Bob O'Brien
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Comments (6)
Re: Draft of Comment Letter For SEC Reg SHO Request For Comments By n-tres-ted on 8/16/2006 6:55 PM
Bobo,

Someone might want to suggest they put some teeth into Reg SHO in the nature of enforcement penalties substantial enough to make such violations unprofitable.
Re: Draft of Comment Letter For SEC Reg SHO Request For Comments By Niel Storts on 8/16/2006 6:55 PM
Already make my comment. Make sure you give us all fair warning to sign the capping petition in time for most of us to sign on. Keep up the good fight. Don't let the tiff about TA get in the way. <>
Re: Draft of Comment Letter For SEC Reg SHO Request For Comments By mhatmccane on 8/16/2006 8:25 PM
I already sent my comments in - 3 or 4 times, but will be happy to sign the petition.
Re: Draft of Comment Letter For SEC Reg SHO Request For Comments By Wonder Boy on 8/16/2006 9:07 PM
Quite a while back, I posted that Cox was at a crossroads. He had to decide to either be a politician or a regulator. I am still on the fence, but I like some of his new appointments---we will see what happens. Still, I would like to see the 'resignations' of some folks that we all love and cherish!

My most recent approach to Grassley and Specter has been to ask for an independent investigation---per BoBo---but I wanted to know WHY the SEC took it upon themselves to overrule laws from '33-'34 that laid things out quite nicely as far as I could see and did they REALLY have the 'authority' to change things. In the furtherance of my 'Financial Jihad', I bypassed Senator Shelby and wrote to each member of his 'committee' with attachments of the e-mails that I originally sent them and to Senator Shelby (over a year ago!) and Senator Shelby's 'canned' response. ( I am sure that all have read THAT letter--he sent it to everyone!). My question to them was why they seemingly went along with Shelby's cancelling of the meeting over NSS particularly since other areas of Government were now wondering what is going on at the SEC.

Truely, I am a mild mannerd, shyish, cautious type of person, but someone once told me 'Do great things all of your life and no one remembers---fart in the room ONE TIME and no one FORGETS!' Could it be that we all need to eat more bran?
Re: Draft of Comment Letter For SEC Reg SHO Request For Comments By phonesll on 8/17/2006 11:52 AM
I'll answer WonderBoy's question concerning whether the SEC can arbitrarily change the laws on the books. The technical answer is no they can't. However, Congress has always given leeway to federal agencies in interpreting the law. In reality, Reg SHO is a direct violation of the law that was passed in 1934. However, just like the IRS interprets tax laws, so too does the SEC interpret securities law. The real root of the problem is Congress. If someone had the time and a lot of money, they could sue the SEC and in about 7-10 years, once it gets to the Supreme Court, they could probably force the SEC to actually enforce the law. That is one of the major problems in our judicial system. In many cases, the amount of money it takes to get a law enforced is disproportionate to the damage that is getting done by not enforcing it, but yet, if you don't have the money, you can't do anything about the law not being enforced.
While sending comments to the SEC on their new Reg SHO law is worth doing, I won't hold my breath that it will do any good. The SEC has shown itself to be a political agency and not a law enforcement agency. I don't believe anyone there, including Cox, believes there are enough people who understand the raping that is going on in the markets and therefore, does not have to be too concerned. Only if and when a significant number of companies decide to leave the U.S. markets or a truly disastrous financial collapse of a major bank(due to illegal trading) occurs, will the SEC and or Congress decide to act. Politics is run by money and there is no more money than in the financial markets. There is an extreme lack of morality as well. Put those two in combination with one another and you get what we have in our markets today, just like back in the late 20's and early 30's.
Re: Draft of Comment Letter For SEC Reg SHO Request For Comments By Wonder Boy on 8/17/2006 1:57 PM
Phones.......

Thank you very much for your explanation.

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