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To: Daniel King who wrote (787)	8/13/1999 3:16:00 PM
From: KENNETH DOAN	Respond to of 1956

Danny, If your broker have the shares to lend you, you can short it at anytime. It does not matter when it was IPO.

To: Daniel King who wrote (787)	8/13/1999 3:25:00 PM
From: Don Pueblo	Respond to of 1956

The rules changed a few months ago. If your clearing firm has shares of the IPO to loan, (meaning they have it on 70% margin; not the usual 50%, so you pay 70% of the price of the stock) you can short an IPO. You MUST have the shares available to short. I called my clearing firm about this, and several people who were Series 7 licensed DID NOT know about the rule change. You can short an IPO on Day 2 IF IF IF the firm has the shares to loan you, and MAKE SURE you find out what the margin percentage is BEFORE you pull the trigger.