From: DenizkurtE@aol.com
Sent: Tuesday, October 28, 2003 12:14 PM
To: rule-comments@sec.gov; schockL@sec.gov
Cc: DenizkurtE@aol.com
Subject: Short Sale Rule Proposals

Dear SEC Staff:
 
Below is a list of concerns I have regarding short sales. I would like to voice 
my opinion and suggestions on the issue and they are listed below. If you have 
any questions regarding any of the proposals I am available to clarify my position.

 
SHORT SELLING RULE PROPOSALS
  1.. All short positions must be monitored by the SEC 
  
  2.. All short position totals updated daily and posted on the data sheet along 
  with price, high, low, close, previous day close, short, previous day short; 
  that way all important information directly impacting an investors investment 
  can be viewed quickly 
  
  3.. All short positions broken down by Market Maker on each exchange; 
  manipulation can be easily monitored if this is done 
  
  4.. All short positions, outstanding number of shares and float all updated 
  daily and grouped together as those details impact a shareholder the most on 
  all NASDAQ, AMEX, NYSE, OTCBB  stocks 
  
  5.. SEC must make sure the number of shares short do not exceed the Float. 
  This must be monitored for NYSE, AMEX, NASDAQ and especially the OTCBB stocks 
  
  6.. All shorting of stock from brokerages outside the US needs to be monitored 
  for economic terrorism reasons. The best way to hurt the US is to harm its' 
  capitalist society. By shorting and driving US stocks into the penny levels 
  incredible harm has been done to corporations that employ millions of people. 
  
  7.. SEC must monitor closely all short positions by brokerage houses with 
  investment banking arms. Too many of them are doing Convertible Financing and 
  PIPE Financing and then shorting the stock to reap profits. 
  
  8.. Market Makers who are upside down should not be allowed to short until 
  buying interest is gone. Close monitoring of their activities regarding this 
  is imperative. 
  
  9.. Punishment by brokerage firms and market makers who break short selling 
  rules should be punishable by prison and not a fine. That will make the abuses 
  stop. Paying a fine is obviously not enough of a deterrent. When brokers are 
  willing to pay 100 million in fines like those imposed for other reasons these 
  past few years then it is obvious enough money is being made that even a 
  100 million fine is not enough of a deterrent to the criminals 
  
  10.. Market Makers should be making most of their money from orderflow not from 
  trading in the securities they make a market for. Since they have access to all 
  orders they have an upperhand over average investors and should not be taking 
  advantage of that position; CNBC reported market makers make 80% of thier income 
  from profits on stocks they make a market in and 20% from order flow - Shouldn't 
  it be the other way around?
  
Thank you for your time.

Erol Denizkurt
4548 Andover Way F303
Naples, FL 34112
Phone: 239-417-4348
Fax: 240-331-5618
DenizkurtE@aol.com