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NCANS Comment Letter to the SEC

Location: Blogs Bob O'Brien's Sanity Check Blog    
Posted by:   bobo 9/4/2006 8:12 AM

UPDATE: Folks, here is the NEWLY UPDATED NCANS letter to the SEC (as of 12AM, EST, 9/5) on Reg SHO. Please take time to read it through. It has gotten a section on penalties and loss of licensure, and a more fleshed-out section on numerical marking of individual securities - the better to ensure a one-for-one ratio of security entitlements to bona fide securities. It works with car VIN numbers and banknotes, so why not stock?

Also, we've got the first 160 or so signatures. I've been getting emails telling me that the fax is busy, so please keep trying - or email me a jpeg of your signature, or worst case, just an email authorizing me to use your name (but provide all contact info, please). If it doesn't go through, keep trying, and spread the word for anyone interested to demonstrate your support. You are either part of the problem or part of the solution - and this is where you get to decide which you are.

------------------

Special thanks to Tommytoyz for his mountain of effort in giving birth to this document, as well as to Lynn for countless hours of editing and fact-checking. Also, thanks to Patrick, and the host of others who provided input and suggestions.

This letter is intended to provide solutions, and deliberately stays away from pointing fingers or apportioning blame. Dr. Trimbath's masterful letter does an unparalleled job of describing how we got where we are, as does Dave Patch's letter. I can't think of any way of improving their observations, so we stayed away from criticism and focused on how to solve the structural problems in the market.

We would like to get as many signature to add to the document as we can, so I will ask everyone to fax a signature, and name and address, to the number below. Here is a signature form to fill out. I'll keep the addresses and phone numbers confidential, but I need them so I can substantiate that the signatures are genuine. The goal is to gather hundreds, if not thousands, of signatures to append to the letter, which will go to the SEC and be posted on the web. Please show your support, and take a moment to send us your John Hancock. And send the link to this blog to everyone you know so they can sign on as well - feel free to post it to message boards, blogs, and chat rooms. More is more. And we have about 10 days.

A fax number has been set up for signature collections. It is 702 946-0934.

Spend some time reading the document, and then get the word out so we can demonstrate support for the suggestions. A few minutes of your time can go a long way, and this is one of the ways you can make your voice heard.

Please do your part.

Copyright ©2006 Bob O'Brien
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Comments (80)
Re: NCANS Comment Letter to the SEC By mister_mindless on 9/4/2006 1:25 PM
bobo,

Do want us to just fax our signatures on a blank piece of paper, along with our addresses, or is there some other way you would like us to do it?
Re: NCANS Comment Letter to the SEC By lynetta32233 on 9/4/2006 1:57 PM
Should there be only one signature per page?

For those of us technologically challenged, and/or dealing with old, recalcitrant fax machines, will there be any list published of those who have signed, so we can verify that our fax "took"?
Re: NCANS Comment Letter to the SEC By edlehrer on 9/5/2006 6:52 AM
Wonderful, wonderful, wonderful!

We have to KICK-OUT these neo-cons and get back the Republican Party again.....

if there is anything left.
pgwc- murder and rape was aided and abetted by the press. By newspaper on 9/5/2006 7:10 AM



Pgwc goes on reg sho and it gets destroyed.

Do you see what has happened here?

Since pgwc went on sho 90% of its market cap has been slashed.

Volume for 13 days on sho was around 25mil

normal volume for a 13 day period off of sho is around 1.5mil

While on sho they reached a new 52 week low

I want you to read this

---

Pegasus Wireless Corporation (OTC: PGWC) - Thursday's shares closed down 33.40% with a price of $3.43. The volume was at 4,644,683. Pegasus Wireless Corporation a leading provider of advanced wireless solutions, is proud to announce that the Company's President and CEO, Jasper Knabb, has been invited to throw the ceremonial first pitch tonight, August 29, 2006 when the Oakland A's take on the Boston Red Sox at MacAfee Coliseum in Oakland, California. The pitch will take place prior to the game, which is scheduled to begin at 7:05PM Pacific Time. The game will air on local stations in California.

------

Notice something odd? Usually when there is big price movement like that the news item is relevant to the story. It usually reads something like- Amazon down 30% on bad profits, or Msft down 20% because of lawsuit.

I have never seen this before

Stock down 90% in 2 weeks on NO news. The only thing they could find is the first pitch story.

So why all the negative press?

And why all of it in the last 2 days?

NY POST NY TIMES Barrons Motley Fool. They all have the same story. All negatives and no positives

Now there are no recent negatives so lets go back 5-10 years to find something ANYTHING to tarnish this company and the CEO.

I think they overdid it with pgwc and they needed the media to provide cover. And they needed them to do it quick.

You can just see how it went down cant you? Hedge fund calls all the usual suspects and they say

"Write something BAD about PGWC, and do it NOW."

"We cant just have a stock go down 90% on NO news."

So they went back 5 years found and found some reverse mergers. Yeah lets use that. how is a RM bad news Ted Turner used one to start CNN.

Then they brought out the big guns. ARREST... Sex Offender... Frivolous Lawsuits.

Nevermind the fact that Knabb HAS a clean record cause the charges were dropped and he was let go.

And some dude that knabb knew years ago who is a sex offender now but was not then.

Knabb has nothing to do with him now and he was not a Sex offender when he met him back then.

I am surprised they did not write how he forget to put the toilet seat down once when he was with his girl.

The moral of this story is. If you talk about shorts or try to fight them they will kill your stock.

Now i felt bad for knabb until he mentioned "I am not ostk" then i lost a little sympathy for the guy.

Re: NCANS Comment Letter to the SEC By newspaper on 9/5/2006 7:28 AM
People new recruits to the cause are there for the grabbing. Go to the yahoo pgwc message board. Check the large amount of bashers. They are killing the longs. I can’t do it alone I must have brought at least 5 new people to this site and opened their eyes to a Bear Raid.

They longs on PGWC need your help.

Gary Weiss even talked about PGWC you know it’s a big deal if he talked about it. It is a counterfeit bear raid happening in real time.
Re: NCANS Comment Letter to the SEC By bobo on 9/5/2006 8:07 AM
Folks, I am pleasantly surprised, and am getting tons of faxes. That's the good news. The bad news is that each signature requires about 5 minutes of processing time, to cut and paste it. Add that up times 100 or so per day and you start to get the idea. I'm not going to be hugely responsive for the next 10 days as this is filling up all my free time.

I will put a copy of the letter up with all the signatures I've processed in a day or so. I may have to stop at a few hundred, and simply forward the entire thing on to the SEC, with a tally of the total number received and copies of all the faxes.

Please keep spreading the word. It would be nice if this had a lot of signatures supporting it.
Re: NCANS Comment Letter to the SEC By beegdawg on 9/5/2006 8:23 AM
The letter itself is fine. I have only one comment. A CC of this letter must be sent to someone who runs the DOJ - Spector or Hatche, etc.. Left to ist own initiative, I am convinced that the SEC intends to do as little as is possible about naked short selling since every high level SEC attorney, including Cox, knows that his next job will likely be as an attorney who is working for a hedge funds.

A former CEO for a very large company told me very early in my career, "shit never rolls uphill". And, for this letter to have any chance of even being read by Cox or someone else near his level, we must make certain that the shit will roll downhill!!

Regards,

b d:?|
Re: NCANS Comment Letter to the SEC By sealman29 on 9/5/2006 8:31 AM
Thanks to all who helped put the NCANS letter together and to those leading the crusade against NSS and FTD The SEC must be accountable to enforce our securities laws.
EXCELLENTOMUNDO letter. Signed and faxed this am.
Re: NCANS Comment Letter to the SEC By Dan Meinwieser on 9/5/2006 8:33 AM
Naked shortsellers are, in my opinion the scum of the earth and should be removed from the society. They are criminals who have the boldness to spit in the faces of all authorities and continue their rampant daily crimespree against unsuspecting honest investors.
Re: NCANS Comment Letter to the SEC By sealman29 on 9/5/2006 8:50 AM
Bobo, is there any way or benefit to makeing the NCANS letter public information or perhaps submitted as an amicus brief to all current and future lawsuits regarding NSS and FTD? It might be one more bullet for all the good guys cases.
The letter might also make an excellent full page statement in a national newspaper like USA Today, Barrons, IBD.
Re: NCANS Comment Letter to the SEC By Sean on 9/5/2006 9:29 AM
A little off topic Another slap on the pinkie for big brokerage house for shorting!!!!

Morgan Stanley Fined $2.9 Million

WASHINGTON — The NASD, a private-sector provider of financial regulatory services, said Tuesday it fined Morgan Stanley $2.9 million for "extensive violations" dealing with reporting obligations, short sales and a slew of other NASD, Securities and Exchange Commission and other rules.

The investment firm's violations date back to 1999, the National Association of Securities Dealers, said, adding that both Morgan Stanley & Co. and Morgan Stanley DW Inc. will provide it with corrective actions to ensure regulatory compliance.

Morgan Stanley "undertook independent, internal reviews to determine the causes and extent of their trade reporting problems, provided their findings to NASD, and were otherwise highly cooperative with NASD's investigation," said Tom Gira, NASD executive vice president, in a statement.

NASD said Morgan Stanley did not admit or deny wrongdoing, but agreed to the entry of NASD's findings.

Morgan Stanley's shares rose 27 cents to $67.10 in morning trading on the New York Stock Exchange.

http://www.chron.com/disp/story.mpl/ap/fn/4163886.html

Re: NCANS Comment Letter to the SEC By virakiller on 9/5/2006 11:09 AM
WARNING AMERICA
Financial terror alert

look up name Dr Herbert Batliner

google his name and see for yourself
Re: NCANS Comment Letter to the SEC By William P Bishop on 9/5/2006 11:26 AM
This may be my problem, but may be yours. I'm trying to get the NCANS letter up and all I get is a pop up stating the file is damaged and can't be repaired.
Re: NCANS Comment Letter to the SEC By Fernando on 9/5/2006 11:28 AM
"executed thousands of short sales transactions without ensuring that the firm could deliver or arrange to borrow the securities by the settlement date;"


http://www.nasd.com/PressRoom/NewsReleases/2006NewsReleases/NASDW_017308




For Release:
Contacts: Tuesday, September 5, 2006
Nancy Condon (202) 728-8379
Herb Perone (202) 728-8464







NASD Fines Morgan Stanley Firms $2.9 Million for Widespread Violations of NASD Rules


Number and Scope of Violations Indicate Extensive Reporting Problems at Both Firms






Washington, D.C. — NASD announced today that it has imposed fines totaling $2.9 million against Morgan Stanley & Co., Inc. (MSCO) and Morgan Stanley DW Inc. (MSDW) for extensive violations dealing with reporting obligations, best execution, short sales, and a range of other NASD, Securities and Exchange Commission (SEC) and Municipal Securities Rulemaking Board (MSRB) rules.



In addition to the fines, both firms will provide reports to NASD detailing the corrective actions completed and the ongoing corrective actions being taken to ensure that each firm has adequate policies, procedures, systems and training necessary to ensure regulatory compliance.



"MSCO and MSDW had numerous types of reporting violations and the scope of those violations indicated a failure to adequately address compliance needs of the firms," said NASD Executive Vice President Tom Gira. "But MSCO and MSDW also undertook independent, internal reviews to determine the causes and extent of their trade reporting problems, provided their findings to NASD, and were otherwise highly cooperative with NASD's investigation. The firms' cooperation is reflected in the sanctions."



NASD found that MSCO and MSDW each committed numerous violations of federal securities laws, NASD rules and MSRB rules during the seven-year period from 1999 to 2006. Among the most significant was a series of violations of the Order Audit Trail System (OATS) reporting requirements, which resulted from MSCO's pervasive inability to properly track and report OATS data. Additionally, MSDW had numerous regulatory violations involving the firm's failure to adequately price, sell and report corporate and municipal bond transactions, and will make nearly $30,000 in restitution payments to affected customers. NASD also found that both MSCO and MSDW failed to implement effective supervisory systems and written supervisory procedures necessary to ensure compliance with federal securities laws, NASD rules and MSRB rules.



NASD also found a variety of other regulatory violations at both firms. NASD found that MSCO:

failed to timely report or incorrectly reported thousands of transactions through the Nasdaq Market Center in Nasdaq National Market securities, OTC Equity securities and listed securities;


executed thousands of short sales transactions without ensuring that the firm could deliver or arrange to borrow the securities by the settlement date;


failed to execute hundreds of customer trades at the best available price, and will make nearly $5,000 in restitution payments to affected customers;


failed to report or incorrectly reported thousands of transactions in corporate bonds; and


created locked and crossed market conditions in hundreds of instances.
NASD found that MSDW:

failed to send, or failed to send in a timely manner, required documents to hundreds of customers in connection with municipal bond transactions;


failed to report or incorrectly reported thousands of transactions in corporate and municipal bonds; and


failed to enforce the firm's written supervisory procedures with respect to municipal bonds.
In settling these matters, MSCO and MSDW neither admitted nor denied the charges, but consented to the entry of NASD's findings.



Investors can obtain more information about, and the disciplinary record of, any NASD-registered broker or brokerage firm by using NASD's BrokerCheck. NASD makes BrokerCheck available at no charge to the public. In 2005, members of the public used this service to conduct more than 4.3 million searches for existing brokers or firms and requested more than 194,000 reports in cases where disclosable information existed on a broker or firm. Investors can link directly to BrokerCheck at www.nasdbrokercheck.com . Investors can also access this service by calling (800) 289-9999.



NASD is the leading private-sector provider of financial regulatory services, dedicated to investor protection and market integrity through effective and efficient regulation and complementary compliance and technology-based services. NASD touches virtually every aspect of the securities business - from registering and educating all industry participants, to examining securities firms, enforcing both NASD rules and the federal securities laws, and administering the largest dispute resolution forum for investors and registered firms. For more information, please visit our Web site at www.nasd.com.









About NASD | Press Room | Resources | Career Opportunities | FAQ | Site Map | Contact Us

©2006 NASD. All rights reserved. | Legal Notices and Privacy Policy.

Re: NCANS Comment Letter to the SEC By newspaper on 9/5/2006 11:32 AM
SECURITIES AND EXCHANGE COMMISSION
17 CFR PART 242
[Release No. 34-54154; File No. S7-12-06]
RIN 3235-AJ57
Amendments to Regulation SHO
AGENCY: Securities and Exchange Commission.
ACTION: Proposed rule.
SUMMARY: The Securities and Exchange Commission is proposing amendments to Regulation SHO under the Securities Exchange Act of 1934 (Exchange Act). The proposed amendments are intended to further reduce the number of persistent fails to deliver in certain equity securities, by eliminating the grandfather provision and narrowing the options market maker exception. The proposals also are intended to update the market decline limitation referenced in Regulation SHO.
DATES: Comments should be received on or before September 19, 2006 .

http://www.sec.gov/rules/proposed/2006/34-54154.pdf#search=%22Reg%20SHO%20grandfather%20provision%22

Re: NCANS Comment Letter to the SEC By sanddollar on 9/5/2006 12:36 PM
Are there any requirements for a signing person? Specifically, is my minor child a valid signature, since they are impacted through my investments?
Re: NCANS Comment Letter to the SEC By lewis ncdermott on 9/5/2006 1:16 PM
My wife and I have lost money because certain groups of brokers have taken advantage of small investors. We applaud your efforts to do something about this problem. Our signitures have been faxed.
Re: NCANS Comment Letter to the SEC By davidn on 9/5/2006 1:56 PM
I agree with the "shit rolls downhill" comment. It is imperative that this go to the DOJ.

Look at comment letters dating back a decade - the SEC couldn't care less about the share counterfeiting problem.

Bobo, I suggest you scan the letters with signatures and post them online. That way, we can print them out and send copies to our local representatives and local media.
Re: NCANS Comment Letter to the SEC By Donovan on 9/5/2006 2:01 PM
Naked shorting is a fraud. How can any individual investor want to invest in a system that allows insiders to steal their savings while the SEC and Administration turn a blind eye?
Re: NCANS Comment Letter to the SEC By 1991 Interim Report on Share Counterfeiting on 9/5/2006 2:10 PM
Look at the snippet from 1991. What happened to the report? It didn't make it from interim into the archives:

"In particular, the subcommittee is investigating widespread anecdotal reports of "naked" short selling" in certain stocks..."

They KNOW all about share counterfeiting. The job of the SEC is to keep investors from knowing.

http://books.google.ca/books?id=ym_KLlMiDEcC&dq=sec+naked+shorting++-&q=sec%20naked%20shorting%20%20-&pgis=1
Re: NCANS Comment Letter to the SEC By From 15 Years Ago!!!!!!!!!!!!!!!!!!!!!!! on 9/5/2006 2:15 PM
http://books.google.ca/books?id=aEY3SDf_8uYC&dq=sec+naked+shorting++-&q=sec%20naked%20shorting%20%20-&pgis=1

Short-selling Activity in the Stock Market: The Effects on Small Companies and the Need for...
By Consumer, and Monetary Affairs Subcommittee United States. Congress. House. Committee on Government Operations. Commerce
Re: NCANS Comment Letter to the SEC By ginger on 9/5/2006 2:41 PM
They may have received it but I don't think they read this one by R. Cromwell Coulson. Chief Executive Officer, Pink Sheets.

Cromwell, send it again!

http://www.sec.gov/rules/petitions/petn4-500.pdf#search=%22sec%20%2B%20naked%20%2B%20shorting%20%2B%201991%22
Re: NCANS Comment Letter to the SEC By Harold E Hoerich on 9/5/2006 5:40 PM
Re Page 19 of letter:
Reference to 'short interest in the U.S. Markets should be limited to 50% of issued securities."
Shouldn't that read 5%?
Re: NCANS Comment Letter to the SEC By Juddytwostep on 9/5/2006 5:48 PM
Count me in....the flashlights are starting to shine on the cockroaches and they will be scrambling.....The predators who have been preying on your nest eggs will be exposed...and thanks for your great and tireless efforts...Dirty and EB, one in the same....2 Step!
Re: NCANS Comment Letter to the SEC By HighHopes on 9/5/2006 7:06 PM
This letter is a MASTERPIECE of fine work. If the SEC ignores it, then Congress must take action to enforce the intent of the 1933 and 1934 Security Acts. Each member of Congress should receive and read this letter.
Re: NCANS Comment Letter to the SEC By NWislander on 9/5/2006 9:26 PM
An excellent job: kudos to you all. Faxed my signature. Just sent a contribution to NCANS so you can hire a trustworthy temp. to help with signatures? or Express Mail to the SEC. Anyway, my thanks for everyone's efforts.
Re: NCANS Comment Letter to the SEC By Eliminate Shorting on 9/6/2006 3:51 AM
Bobo,

Why don't you try to send a copy with all the signatures to each elected representative of this country. Make photocopies and send them.

BTW, I have faxed my signature page to you yesterday.
Re: NCANS Comment Letter to the SEC By hhawes on 9/6/2006 3:58 AM
Where's the list of signatures?
Re: NCANS Comment Letter to the SEC By Transparency on 9/6/2006 3:58 AM
http://biz.yahoo.com/ap/060906/china_shanghai_scandal.html?.v=1

Shanghai Faces Biggest Scandal in Years

""This is not a simple case of someone embezzling pension funds under his management. It's rather the predictable result of China's partial pension reforms and the highly secretive manner in which local officials manage these funds," says Mark Frazier, a professor of government at Lawrence University in Appleton, Wisconsin.

Among those felled so far is Zhu Junyi, the city's labor bureau chief who oversaw the pension funds. He is accused of taking bribes and siphoning money from social security funds, the official Xinhua News Agency said."
Re: NCANS Comment Letter to the SEC By The fun stops when the money runs out on 9/6/2006 4:01 AM
http://money.cnn.com/2006/09/06/news/companies/brokerage_stocks/index.htm?source=yahoo_quote

Party may be over for investment banks
Analysts are slashing estimates for brokerage firms. The best days for the industry may be over, for now.
Re: NCANS Comment Letter to the SEC By davidn on 9/6/2006 6:04 AM
I see these form letter replies and think if we would just stop using the phrase "naked short selling", it would make it impossible for them to go into the diatribe about the value of "short selling" and how the SEC reg. SHO is fixing it. It's "share counterfeiting".

http://investigatethesec.com/senator_dole.pdf
Re: NCANS Comment Letter to the SEC By bbhindyou on 9/6/2006 6:13 AM
I want to frame a copy with signatures .Then I will have a place to point and say " I told you so" If this all leads to the crash in the markets .The only deniability the authoritys in charge of this will have is a lack of information. This pretty much takes care of that.I'll frame a copy and make a list of all the officials I sent a copy to .History is made every day. This is a nice piece.
Re: NCANS Comment Letter to the SEC By bobo on 9/6/2006 6:31 AM
We have had a few people express concern over the possibility of someone using the signatures on the web for some sort of identity theft - remote given that the state of the resident isn't divulged, nor the town, and that there is some distortion from the fax and digital formatting. So I am keeping it off the web for now. I have received some crank emails saying remove my info, I don't know how you got it - uh...you faxed it to me? So far none of those turn out to have their signatures on the piece, so it is just bad guys doing what they do.

But still, don't want to be sorry later, so down they came.
Re: NCANS Comment Letter to the SEC By hhawes on 9/6/2006 7:54 AM
How about just a list of names? After all, 99% of us are in the phone book which would be a hell of a lot better source for ID theft than this....just a thought. Ok either way with me.
Re: NCANS Comment Letter to the SEC By piddly_sum on 9/6/2006 8:21 AM
I agree with hhawes, just type a list of the names. When you deliver it to the SEC state that you have the signatures on file.

It will also save you a lot of time compiling the list.
Re: NCANS Comment Letter to the SEC By friendofthedevil on 9/6/2006 9:22 AM
I was happy to see my name on the page. I think it is a good idea to at least print the names so that we can make sure you received our signatures. Also, I would contribute to a campaign to pay for the letter to be published in the WSJ or the NYTs. How about it?
Re: NCANS Comment Letter to the SEC By bobo on 9/6/2006 9:37 AM
The letter is far too long to be published in a paper.

I'll look at publishing the names. That is a lot of names to type...
Re: NCANS Comment Letter to the SEC By friendofthedevil on 9/6/2006 10:04 AM
Thank you. We don't take for granted the work you do.

Re: NCANS Comment Letter to the SEC By friendofthedevil on 9/6/2006 10:19 AM
On second thought, we could help. I can type up one hundred names today if you wish. Just tell me how to give you my email privately.
Re: NCANS Comment Letter to the SEC By wriskit on 9/6/2006 7:32 PM
Great letter! Cuts through the SEC nonsense with the sharp knife of common sense. But the powers behind the FTD scheme will use every means to stifle this essential reform. We must maintain a constant pressure of publicity if we hope to prevail in our fight for simple justice and fairness.


















Re: NCANS Comment Letter to the SEC By bobo on 9/6/2006 7:48 PM
We are now at about 245 or so signatures. And climbing. Please keep sending them in. More is more. Really.
Re: NCANS Comment Letter to the SEC By how is it out there on 9/7/2006 6:17 AM
about more signatures...

can't explain such complex matter to my acquaintenances. I lose them aftaer awhile.
some don't want to fax their signature, address & phone to a fax # they don't know about.
Re: NCANS Comment Letter to the SEC By bbhindyou on 9/7/2006 10:55 AM
Lets try vectoring out by alerting union members to contact their pension /retirement reps about the security of the funds in the accounts due to this situation.Buds last entry seems to indicate the funds not directly in stocks may not be safe either.If the institution holding your funds has used them for collatoral on stock trading then they may be in danger.
Re: NCANS Comment Letter to the SEC By bobo on 9/7/2006 9:06 PM
How is it out there:

Have them email me their name, address and phone number, absent signature, with a statement that it is OK to put their name on the PDF being sent to the SEC.
Re: NCANS Comment Letter to the SEC By let's think security on 9/8/2006 6:14 AM
just a afriendly reminder. not to denigrate your commonsense...hell, you figured it our for us but since you are very busy, & perhaps have helpers...
when you are finished with faxes of our signatures...make sure these photocopies are SHREDDED!

again thank you for all your work
Re: NCANS Comment Letter to the SEC By ckza on 9/10/2006 8:21 AM
Hi Bob:

This may or may not have been covered already, I don't know. Is it possible that the language, "the undersigned have been negatively affected by..." is causing hesitation on the parts of some who aren't familiar, or couldn't be sure that this is true for them personally, therefore; aren't comfortable in signing?

I was hoping you would have had multiples of the couple of hundred signatures by now.
Re: NCANS Comment Letter to the SEC By bobo on 9/10/2006 1:21 PM
I will expunge the records of all signatures after the SEC has been sent the pdf and confirmed receipt.

Let me be clearer. Please send me via email your statement "I supoort the NCANS SEC letter and all the proposals therein" along with your contact info and I will simply add your name to the list.

NCANS.mgr@gmail.com
Re: NCANS Comment Letter to the SEC By ronald t. angelo on 9/12/2006 10:50 AM
I am in full agreement with and gratefull for the composition of the letter. It's terms reflect accurately what needs to be changed and done to protect the hard earned saving of small investors in U.S stockmarkets.
Re: NCANS Comment Letter to the SEC By Sherryazure on 9/13/2006 3:18 PM
On behalf of Pandaman, and Jim (both passed) and went through the horror of the first Bear Raid on NFI.... I still have their emails of how it affected them as it did most of us then, and now... Many years later, here we are... Best Sherry
Re: NCANS Comment Letter to the SEC By Penny and John Pittman on 9/13/2006 7:22 PM
The SEC needs to follow the rules they implemented with Reg Sho and force buy-ins for FTD's. Those who steal by never intending to borrow shares which they sell short should be in jail. So should those who aid and abet them. Tiny fines of naughty brokerages mean nothing because they are making huge sums in this "game" of theft.
Re: NCANS Comment Letter to the SEC By Ronald M. Vander Veen on 9/13/2006 9:26 PM
I supoort the NCANS SEC letter and all the proposals therein
Re: NCANS Comment Letter to the SEC By Edward M. Sawtelle on 9/14/2006 12:46 PM
I totally indorse the letter by NCANS to the SEC. The SEC should provide the changes suggested and institute the penalties proposed.
Re: NCANS Comment Letter to the SEC By Jfitz on 9/14/2006 12:54 PM
I'd prefer to snail mail the document and my signature. What is the postal address?
Re: NCANS Comment Letter to the SEC By tommytoyz on 9/15/2006 10:56 AM
foreign investors are welcome to sign the letter as well. US markets and naked short sellers accept money from foreigners and markets are truly global now.
Re: NCANS Comment Letter to the SEC By RobK on 9/18/2006 10:35 AM
Bobo,

I don't know if it is too late, but may I suggest a few grammatical corrections.

On Page 8, you start to list the consequences of eliminating the market maker exception to pre-borrow. The titles of each enumerated consequence do not currently match grammatically:
I include the ( ) merely to indicate grammatical use, ie, ‘the consequence will be: (To) reduce …’; or ‘our recommendation is (To) implement...’
1: (To) Reduce ….
2: (To) Reduce …
3: (To) Increase …
4: (Of) Stopping … s/b (To) Stop
5: (Of) Increased … s/b (To) Increase
6: (To) Maintain …
7: (Of) Strengthening … s/b (To) Strengthen


Again, starting on Page 10, you begin a list of further recommendations.
1: (To) Implement universal delivery
2: (To) Implement universal pre-borrow
3: (To) Implement universal locate
4: (To) Implement buy-in
5: (??) Security Entitlements … how about (To) ‘Enforce Security Entitlements’
6: (??) Centralized Audit & Ctrl Sys… go back to (To) ‘Implement Centralized...
7: (To) Limit total short interest
8: (To) Publish short interest daily
9: (Some) Proposals on … how about (To) ‘Include the following additional regulations’
10: (??) Revocation of … how about (To) ‘Institute a policy of revoking…’


Just trying to help.
Re: NCANS Comment Letter to the SEC By robert l miers on 10/26/2006 3:52 PM
if you continue to let the wealthy take advantage of ordinary investors, you fail at your mission, your country, and honest families who invest in america. history will not treat you, your personal honor, or your family names well.
Re: NCANS Comment Letter to the SEC By marc81 on 9/4/2006 2:36 PM
Bob,

How about providing an email address for all of us without convenient access to a fax machine who want to add our signatures?
Re: NCANS Comment Letter to the SEC By I_O on 9/4/2006 2:48 PM
BunnyMan,

How about a signature sheet with 4 to 8 signature positions with the information needed (address, etc.), that we can print off and either FAX or scan and email as a PDF file.
Re: NCANS Comment Letter to the SEC By Bobo on 9/4/2006 3:15 PM
OK. You can email me at ncans.mgr@gmail.com. And I am uploading a signature page in a few minutes.
Re: NCANS Comment Letter to the SEC By ginger on 9/4/2006 3:57 PM
I don't have a fax. Should I email a PDF file using my scanner?

Re: NCANS Comment Letter to the SEC By LinnBenton on 9/4/2006 3:59 PM
Will you be sending this letter to Sen. Spector and Sen. Grassley?
Re: NCANS Comment Letter to the SEC By PeggyT on 9/4/2006 4:17 PM
Thanks to all contributors for a really excellent letter!
Re: NCANS Comment Letter to the SEC By bobo on 9/4/2006 4:59 PM
Email me is fine. I will ask Mary to send it to the Senators - or any of you can feel free to send it, as well. I really think the letter closes most of the loopholes, and describes a myriad number of ways the system is currently gamed. The more people who understand the issues, the better.

Again, send your emails to ncans.mgr@gmail.com
Re: NCANS Comment Letter to the SEC By rtway1 on 9/4/2006 5:55 PM
Bobo,
I got a letter from the SEC signed by Gloria Smith Hill thanking me for the letter I sent Cox on Aug. 16. She also pointed out that I talked to one of their atty,s on the Aug. 25 and said if I had further questions to call him. This is the same guy I gave you a number for before. He has also e-mailed me since we last communicated. He also said feel free to call. Did he ever return a message to you yet? Nice job on the letter, give all a pat on the back for me.
Re: NCANS Comment Letter to the SEC By rtway1 on 9/4/2006 5:57 PM
I'll fax you the letter from SEC with the petition.
Re: NCANS Comment Letter to the SEC By nopec2001 on 9/4/2006 6:03 PM
Great letter!! Thanks to all who helped. Hope that the SEC will listen.
Re: NCANS Comment Letter to the SEC By InTheKnow on 9/4/2006 6:37 PM
You nailed it...

SETTLE THE TRADES or SETTLE IN JAIL!
Re: NCANS Comment Letter to the SEC By Bobo on 9/4/2006 6:59 PM
He never responded to my email to him.
Re: NCANS Comment Letter to the SEC By gilteddger on 9/5/2006 3:09 AM
You need to improve the signature form to cater for international investers...
Re: NCANS Comment Letter to the SEC By hawlw3 on 9/5/2006 4:20 AM
I do not have access to a FAX machine. Is there any other way that I can get
my signature in to you? I am retired and 82 years old.
Re: NCANS Comment Letter to the SEC By long_ostk on 9/5/2006 4:30 AM
for those having trouble with faxing or signatures, you could always copy the ncans letter and email it to the SEC saying that you support all that was written.