OTC BOYCOTT BOARD

[Georgia Bard]

One reason the short Uptick Rule has not been removed is because people are cryingout about it. There has been on action taken thus far.

Though is Boycott is Noble and Admirable, it has a lot of flaws. If you focus on one aspect you will get it but the problem is what will you give up.

The answer here is SRO, which has an SRO proposal on rule changes http://www.sec.gov/rules/proposed/34-43860.htm , which most do not understand how that can help. Also the ATS (Which will be extremely difficult to get approved) & ECN as market markers, will take the order flow out of the MMs hands. My Track trading for example you can route your order around MMs directly to ECN except on OTCBBs. I have posted in my last post the method to respond to ECN as an MM for the OTCBB.. Everyone should write and send it in.

However, if we get the ECN trading for OTCBB that still leaves the shorting issue, which is out of control and doing away with the uptick rule will basically kill the market. My letters on this are

11-23-99 http://www.sec.gov/rules/concept/s72499/swancey1.txt File No. S7-24-99, short selling and naked shorting Release number 34-42037 http://www.sec.gov/rules/concept/34-42037.htm

5-12-2000 http://www.sec.gov/rules/proposed/s73199/swancey1.txt File No. S7-31-99 Release Nos. 33-7787, 34-42259, IC-24209, Selective Disclosure and Insider Trading

08-08-2000, I wrote another letter because the OTC MMs change the MM daily reports to reveal nothing and thus began charging for them. My letter is about 75% of the way down the page. http://www.sec.gov/rules/proposed/s73199/0810b01.htm

Short selling rule comments http://www.sec.gov/cgi-bin/txt-srch-sec?text=s7-24-99&mode=Simple
Selective Disclosure Insider Trading comments: http://www.sec.gov/cgi-bin/txt-srch-sec?text=s7-31-99&mode=Simple

Now I am going to address the ECN for OTCBB scenario to be approved immediately but also to put more restrictions on the short selling. Theshort positions in stock are outside the realm of reality. If the SEC romoves the uptick rule then shorters will have a control over the market for a long time. I personally think it is wise to send a comment to the SEC protesting slacking or removal of the Uptick Rule.

There are proposals in place already concerning the very issues of this boycott. But remember gravity the MMs have no resistence to down ward movement. I think if the boycott possibly had any effect at all the MMs would realize that no pressure (buying) would be in the market thus moving it stocks lower will be a piece of cake and not require any money at all.

I think this should be thought about a bit more diliberately.


:=) Gary Swancey