Zhuding International Ltd (ZHUD)

[RiseandShine]

Here is one of the most comprehensive reads ever written:
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Securities and Exchange Commission:
450 Fifth Street, NW
Washington, D.C. 20549-0609

Re: File # S7-23-03

Dear Mr. Katz,

We thank you for this opportunity to offer comments and suggestions in regards to the proposed Regulation SHO. We are of the opinion that the rampant "naked short selling" of stocks and the associated epidemic of failures of "good delivery" and loans made to mask "failures to deliver" that we are currently experiencing, threatens the very core and integrity of our financial system. These problems need to be dealt with IMMEDIATELY, even before the implementation of the proposed Regulation SHO.

As each day goes by, the investment losses pile up, another handful of micro cap companies go bankrupt, and the inevitable loss in investor confidence once this little "industry within an industry" is exposed increases. This is occurring at a time when the system can ill-afford any new scandals involving perceived regulatory apathy. Our comments will first address some specific suggestions and then some generalizations based on 21 years of research on the phenomenon known as "naked short selling."

The term "naked short selling" would thus refer to the selling of legitimate "shares/packages of rights", without first borrowing them. On Wall Street, the reference to "naked short selling" is of a much more heinous nature than the name implies. That which is being sold by unethical market makers, clearing firms, and co-conspirators and purchased by investors is not a legitimate "share/package of rights".


5) In (3) (i) what keeps a crooked MM from just naked short selling through a different proprietary or non-proprietary account once he's caught? Please refer to the Sedona case modus operandi. These people usually work in collusion with many other co-conspirators both on and offshore. A MM caught misbehaving can hand the naked short selling torch to a "buddy MM" for 90 days and return the favor should the "buddy MM" get caught. The emphasis has to be on shutting down the abusive naked short selling of the abusive BROKERAGE FIRMS, NOT JUST THE OFFENDING ACCOUNTS. IF YOU ACTUALLY PUNISH THE BROKERS, THESE CRIMES WILL BECOME LESS PERVASIVE
https://www.sec.gov/rules/proposed/s72303/decosta122203.htm