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