Testimony: Rule Number S7-12-06 Comments on Proposed Amendments to Regulation SHO

Testimony

Rule Number S7-12-06: Comments on Proposed Amendments to Regulation SHO

Robert Shapiro

14 September 2006

I am Robert J. Shapiro, chairman of Sonecon, LLC, an economic analysis and advisory firm in Washington, D.C. From 1998 to 2001, I was Under Secretary of Commerce for Economic Affairs. Prior to that, I was Vice President and co-founder of the Progressive Policy Institute and Vice President of the Progressive Foundation and continue to be a Senior Fellow of the Progressive Policy Institute. I also served as the principal economic advisor to Governor William J. Clinton in his 1991-1992 presidential campaign, senior economic advisor to Vice President Albert Gore, Jr. in his presidential campaign, Legislative Director and Economic Counsel for Senator Daniel Patrick Moynihan, and Associate Editor of U.S. News & World Report. I have been a fellow of Harvard University, the National Bureau of Economic Research, and the Brookings Institution. I hold a Ph.D. and M.A. from Harvard University, a M.Sc. from the London School of Economics and Political Science, and an A.B. from the University of Chicago.

PDF (16 pages): Rule Number S7-12-06: Comments on Proposed Amendments to Regulation SHO

Article: Naked Fines

Article - Media

Naked Fines

Liz Moyer

Forbes, 13 September 2006

The U.S. Securities and Exchange Commission has received a deluge of requests to amend short-selling rules it enacted just two years ago as the New York Stock Exchange continues its efforts to enforce existing regulations.

JPMorgan Chase has become the fifth bank to be censured and fined by the NYSE’s regulatory division for violations of trading rules meant to curb abusive short-selling.

Read full article.

Article: NYSE fines five firms for rule violations

Article - Media

NYSE fines five firms for rule violations

James Langton

Investment Executive, 13 September 2006

NYSE Regulation announced that it has disciplined five firms for a variety of rule violations.

J.P. Morgan Securities Inc. was disciplined for violation of SEC rules on short sales, NYSE order rules and supervisory violations. It consented without admitting or denying guilt to findings of operational deficiencies concerning Regulation SHO, violating NYSE order rules, and books and records and supervisory violations.

Read full article.

Letter: Research Capital Corporation to SEC on Proposed Amendments to Regulation SHO

Letter

Research Capital Corporation to SEC on Proposed Amendments to Regulation SHO

Geoffrey G. Whitlam, Vanessa M. Gardiner

6 September 2006

Research Capital Corporation (“RCC”) and Research Capital USA Inc. (“RECA”) have reviewed both the existing regulation and the proposed amendments and we have the following submission regarding the proposed changes to Regulation SHO and the problems created by naked short sales.

RCC is a Canadian Investment Dealer that is registered with the Investment Dealers Association of Canada (“IDA”). RCC is a full service brokerage firm that provides selfclearing for both RCC and RECA. RECA is a U.S. Broker Dealer registered with the NASD. Both organizations are headquartered in Toronto, Canada.

PDF (4 pages): Research Capital Corporation to SEC on Proposed Amendments to Regulation SHO

Letter: National Coalition Against Naked Short Selling – Failing to Deliver Securities

Letter

National Coalition Against Naked Short Selling – Failing to Deliver Securities

NCANS

Letter to SEC, 5 September 2006

NCANS is a grassroots organization born of necessity. We are supported by and composed of investors on the receiving end of the negative consequences of naked short selling, long-term unsettled trades, and failed securities entitlements.

In addition to investors and participants, our members include corporate executives concerned about the deleterious effect these practices have on their companies, employees and investors, and their negative impact on corporate governance issues like shareholder votes.

Read full letter.

THE DOLLAR HAS NO INTRINSIC VALUE : DO YOUR ASSETS?