Date:    01/31/2000  9:15 PM

Subject: File No. S7-24-99.
 
My name is Bob Carlo, I have been trading stocks for several years, 
currently I have a rather sophisticated system for daytrading set up in 
my home, level 2, real time quotes charts ect.... I am writing to you 
about the short interest rulings that are being proposed , in the hopes 
that you will take into consideration the extent of the damage that is 
inflicted upon the individual investor as dished out by the corporate 
giants that ABUSE the current short interest rules to basicly steal 
money from hard working unsuspecting people. The fraud and manipulation 
is appearently obvious to the SEC because you have outlined your 
concerns in the proposal.Even though the FRAUD is visible it continues 
and in certain circumstances the SEC grants exceptions to the already 
weak rule,basicly granting permision to plunder the accounts of 
unsuspecting investors, more.
"Recently, the Commission has
received a variety of additional requests for relief from the Rule. Some 
of these requests, if granted, would result in fundamental
changes in the operation of the Rule. "> ee, e.g., Letter regarding 
Instinet Corporation Crossing Network, [1992] Fed. Sec. L. Rep. (CCH) ¶ 
76,290 (July 1,
> 1992); Letter regarding Portfolio System for Institutional Trading, 
[1991-1992] Fed. Sec. L. Rep. (CCH) ¶ 76,097
> (December 31, 1991); Letter regarding Off-Hours Trading by the Amex, [1991] 
Fed. Sec. L. Rep. (CCH) ¶ 79,802
> (August 5, 1991); Letter regarding Operation of Off-Hours Trading by the NYSE,
[1991] Fed. Sec. L. Rep. (CCH) ¶
> 79,736 (June 13, 1991); Letter regarding Merrill Lynch, Pierce, Fenner & 
Smith, Inc. (December 17, 1986), published
> with modifications in Securities Exchange Act Release No. 27938 (April 23, 
1990), 55 FR 17949 (Merrill Lynch Letter).
When a system becomes so one sided, in favor of the wealthy companies, 
that its flaws are perhaps the number 1 reason for individual investors 
losing millions of hard earned dollars, there need to be an immediate 
fix. Granted shorting may be a legal means of exercising ones financial 
options and stradegies, the PLAYING MUST BE LEVELED FOR ALL PLAYERS. Any 
practice that is legal should NOT, and I repeat NOT be done clandestine. 
Every transaction should be done in the same open forum that normal 
trading is done. If a stock is being shorted then so be it but why should 
it remain a secret. SHORT INTEREST SHOULD BE REPORTED DAILY, 
AUTEX/BLOCKDATA tabulate the entire days transaction for every market 
maker in every stock listed before midnight of the day that the 
transaction takes place. SHORT INTEREST SHOULD ALSO BE REPORTED AS SUCH. 
Every transaction shorted should listed under a broker/dealer or market 
maker, out in  the OPEN, NOT behind the ALIS OF an ECN, ie instinet. Any 
deep pocketed group or individual can secretly conspire to manipulate a 
stock by shorting it thru an ECN,  BUT ,if they are forced to show 
themselves publicly through a regular market maker then they would be 
less apt to opperate dishonestly. CURRENTLY it is possible and plausable 
for a BROKER/DEALER to openly upgrade a stock initiating investor to buy, 
while on the other hand in the confines and comfortability of the secrecy 
of an ECN they can take up a short position to artificialy feed the 
demand of that same stock knowing full well that as they encourage people 
to buy they are going to make money from them when the price faulters 
directly due to their short position. THIS TYPE OF ACTIVITY HAPPENS 
EVERYDAY, WITH THE BLESSINGS OF THE SEC, AND NEEDS TO STOPPED AND 
CORRECTED.
First and foremost if any transaction is to be considered legally sound 
than it should be able to stand up to being done in a completely 
TRANSPARENT ATMOSPHERE. If anyone or group or company needs to HIDE 
behind a cloak of secrecy than the action being taken must be SUSPECT, 
or ILLEGAL.
Second, EVERY transaction long or short should be REPORTED DAILY. Again 
if any transaction needs to be reported months after it transaction date 
than it must be considered SUSPECT or ILLEGAL.
LAST, this is the information age, EVERYONE should be entitled to the 
same equality of speed of data. If its transacted it should be reported, 
whether it reported daily creates no hardship for the brokers/dealers. 
DEADLINES for reporting and accurate transactions should always be a 
priority to EVERYONE, not just the DEEP POCKETS.
THANK YOU VERY MUCH FOR READING MY RESPONCE 
Robert Carlo