NEWS

June 19, 2009

Re: File No. S7-08-09; Rel. No. 34-59748
Amendments to Regulation SHO

Dear Chairman Schapiro:

The Coalition of Private Investment Companies (“CPIC”) is pleased to submit its comments regarding the above-referenced proposal of the Securities and Exchange Commission (“SEC” or “Commission”) to limit short selling, through several proposed alternative amendments to Regulation SHO. We understand the Commission is seeking to be responsive to numerous requests from investors and Members of Congress that it take action to address the decline in equity prices during the eighteen months prior to the Commission’s proposal. The proposed rules, however, are an inappropriate and potentially costly response to investor emotion, issuer complaints and political pressure. The Commission should not adopt the rules, unless it has empirical data showing that short selling and the lack of short sale price tests has caused or contributed to the pricing of equity securities below fundamental values and that the adoption of a short sale price test will lead to more accurate pricing of securities. Current sentiment notwithstanding, investor confidence will not be served in the long term by the adoption of rules that the Commission itself has acknowledged have no sound empirical basis and may decrease market efficiency, limit price discovery, provide less protection against upward stock price manipulations, increase trading costs, reduce liquidity and impose other potential costs on investors.

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