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Dear AlphaTrade.com:
I am writing to alert you of a very important rule change that is needed to improve the marketplace in your company's stock. I need your help to make regulators turn on the lights and protect investors from the menace of hidden short selling in the OTC market.
And I hope that, after reading this letter, you will take the time today -- or as soon as you can -- to contact the SEC and voice your support for this needed rule change.
As Chairman & CEO of the Pink Sheets, I know perhaps better than anyone the importance of improving the Pink Sheets and OTCBB trading. And I know the devastating impact that small companies face when their market is tarnished by the threat of manipulation.
There is a crisis facing the OTC market today in the lack of short sale position reporting and disclosure for OTC issues. This lack of transparency regarding short selling in the OTC market allows fraudulent acts to go undiscovered and manipulative short sellers to hide.
I believe regulators should fix the problem. Small issuers traded on the Pink Sheets and the OTCBB deserve the same transparency and regulatory oversight of short selling as those listed on Exchanges or NASDAQ.
Therefore, Pink Sheets has petitioned the SEC to cause the amendment of NASD Rule 3360 and require NASD broker dealers to maintain a record of total "short" positions in all customer and proprietary firm accounts in all publicly traded equity securities as well as report this information to the NASD for public dissemination of the short positions by security. The SEC's action is urgently needed to prevent fraudulent acts, expose market manipulation, promote fair principles of trade and protect investors.
Our full rule change request is available for you to read at: http://sec.gov/rules/petitions/petn4-500.pdf and http://sec.gov/rules/petitions.shtml
But I cannot make this important rule change happen without your help. Thus I'm asking you to write a letter on your company's letterhead today, and voice your support to the SEC for the Pink Sheets' Request for Rulemaking Regarding Member Records of "Short" Positions and Reporting and Public Dissemination.
So please send your comments via Email to: rule-comments@sec.gov with a Cc: copy to: pubcom@nasd.com
Or, if it's more convenient, you can mail your comments to:
Jonathan G. Katz
Secretary, Securities Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549With a copy to:
Barbara Z. Sweeney
Senior Vice President and Corporate Secretary, NASD
1735 K Street, NW
Washington DC 20006-1500;Either way, your Email or letter should refer to SEC File No. 4-500. Request for Rulemaking Regarding Member Records of "Short" Positions and Reporting and Public Dissemination of Aggregate Positions by Security.
And finally, please ask others in your company to comment to the SEC, and Email a copy of this letter to your major shareholders, your investment banker, and your trade association. Urge them to get involved, too.
I know I'm asking you to do a lot. But it's important that we make the OTC market transparent and fairly regulated. I think you'll agree that this issue deserves the small amount of your time it will take for you to tell the SEC what you think about this essential rule change.
Remember, the only way to succeed in achieving this rule change is through the public outcry of corporate officers and investors demanding the SEC make this needed improvement to the OTC markets, and there is no substitute for your personal voice in this debate. This important rule change is not going to happen if you remain silent.So please, don't rely on others to get the job done. Write your Emails or letters today. Together, we must win this battle and convince the SEC not to treat the OTC secondary markets for small companies as second class citizens.
Without this rule change your company, your shareholders and securities regulators will be blind to any short selling activity in your stock. The SEC needs to know that the lack of short sale information in your securities is unacceptable and demand they change NASD Rule 3360 immediately.
I'm asking for your help to improve this critical part of the securities market, so that companies like yours will be traded in transparent, efficient and well regulated OTC markets. Please do your part by writing your Email or letter today. Every voice counts in the debate, and yours could be the one that puts us over the top.
Thank you for your time and help in this fight.
Sincerely,
R. Cromwell Coulson
Chairman & CEO
P.S. We can only succeed in making these rule changes with your help. So please, take action today. And once again, thank you very much for your help.Note: To comment to the SEC via Internet, use rule-comments@sec.gov with a Cc: copy to: pubcom@nasd.com
SEC File No. 4-500. Request for rulemaking regarding member records of "short" positions and reporting and public dissemination of aggregate positions by security.
