STA Comments on Ammendments to Reg SHO and Rule 10a-1

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12 February 2007

Dear Ms. Morris:

The Security Traders Association (“STA”) welcomes the opportunity to comment on the Commission’s proposal to remove the tick test of Rule 10a-1, add Rule 201 of Regulation SHO to provide that no price test, including and price test of any SRO, shall apply to short sales in any security, prohibit any SRO from having a price test, and amend Rule 200(g) of Regulation SHO to remove the requirement that a broker-dealer mark a sell order of an equity security as “short exempt” in the seller is relying on an exception from the price test of Rule 10a-1, or any price test of any exchange or national securities association.