The final revision of the NCANS comment letter to the SEC on Reg SHO has been submitted at the SEC site.
You can read the finished product here.
And here is the confirmation:
"Thank you for taking the time to comment on this release.
Your comments for file number S7-12-06 were received on September 18, 2006.
Please save this page for your records.
Comments received from:
Mary Helburn
Executive Director, NCANS.net
Email: NCANS.Mgr@Gmail.com
Comments:
Comments Attached
Attachment 1: NCANS Sept 18.pdf
http://www.sec.gov/cgi-bin/ruling-comments"
Folks, this is a remarkable document, and I am proud to have been able to make a contribution to it. It neatly summarizes the deficiencies in the current rule, and proposes solutions. The addition of the NYSE data just confirms what we already know - any improvement due to Reg SHO is at best wishful thinking and ass covering by bureaucrats. The NYSE didn't see any inprovement, and investors have been robbed for the last 21 months while the SEC pretended their new non-rule was doing anything at all besides helping the bad guys steal more of our retirements. No data is available for the NASDAQ through the same date yet, but if it tracks the NYSE, FTDs are likely as high or higher now then when they started this idiocy. What is known is that the number of issues is higher now. I think we can probably do a fair extrapolation, and call the SEC bald-faced liars. In my most charitable spirit, I would say that the SEC folks who have been chastising us for our concern over being fleeced by Wall Street while they assist have been actively misleading in their reporting of any progress. Last time I checked, staying flat isn't much progress. Increasing the number of affected issues isn't progress.
You can see the raw FOIA data from Dave here. It is also attached as an exhibit in the letter.
Good job, everyone. And thanks to the 1100 folks who submitted their names and info in one week, to be affixed to the letter as an endorsement of its sentiment.
Feel free to print it out, or email it, to your favorite elected officials and journalists.