Rule Number S7-120-06: Comments on Proposed Amendments to Regulation SHO
Robert J. Shapiro
September 14, 2006

''In addition, the new bid test, like the current one, would apply only to exchange-listed and NASDAQ NMS securities, and not to NASDAQ small cap, Over the Counter Bulletin Board, and Pink Sheet securities-the equities that are most vulnerable to such manipulation.7 Finally, the proposal to reform the tick test addresses the timing of short sales relative to the price set by immediately-previous short or long sales, but not the core issue of naked short sales.''

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