NASAA Letter to SEC on Proposed Amendments to Regulation SHO
Joseph P. Borg
NASAA, 4 October 2006
NASAA offers its support of the proposed amendments to Regulation SHO. While we are encouraged that the Commission is adopting a more proactive stance in this area, we believe that much more is necessary in order to regain public confidence in the integrity of U.S. capital markets and protect both the investing public and our nation’s small business interests. NASAA strongly urges the Commission to take all necessary steps to eliminate abusive short selling, and the corrosive practices that surround it, consistent with the Commission’s mission to protect investors, maintain fair, orderly, and efficient markets, and facilitate capital formation.
PDF (22 pages): NASAA Letter to SEC on Proposed Amendments to Regulation SHO
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
Susanne Trimbath to SEC on Proposed Amendments to Regulation SHO
STP Advisory Services, LLC, 29 August 2006
I am a Ph.D. economist doing research and consulting in finance and economics. I am formerly Director of Transfer Agent Services for Depository Trust Company in New York, and Operations Manager for Pacific Depository Trust Company and Pacific Securities Clearing Corporation in San Francisco. I also was Senior Advisor for KPMG on the USAID Capital Markets Project to design and implement trade clearing and settlement operations during privatization in Russia. Over the last three years I have been a paid advisor to companies, investors and law firms on the issues addressed by Regulation SHO. My comments will reflect my expertise in economic analysis of law and market efficiency, plus securities processing operations.
PDF (14 pages): Susanne Trimbath to SEC on Proposed Amendments to Regulation SHO