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To: R.E.B. who wrote (106)5/20/1998 10:03:00 AM
From: Robert Dwyer  Respond to of 143
 
I called NASD and the Amex. NASD has no policy for reporting short positions in BB stocks. Shorting can done on an unlimited basis providing that the shorting firm "determines" that the stock can be borrowed. They indicated that they do have some sort of 'secret' means of survelliance but they would not disclose what that involves.
Bottom line: there is no public disclosure of short positions on BB stocks and only those shorting know for sure.

Regarding the Amex, they have more formal rules regarding shorting that include an 'agreement to borrow'. When I posed the hypothetical of a large short position 3 to 4x the actual public float, they did not know if they had a rule regarding covering this position upon listing of such a security. I was told by one party 90 days...by another, that there is no policy. Amex officials are researching it and will get back to me. I will post the response when I get it.

Bob



To: R.E.B. who wrote (106)5/20/1998 3:44:00 PM
From: Robert Dwyer  Read Replies (3) | Respond to of 143
 
Gkis will be AMEX listed as of Thursday May 21, 1998. Just came over the wire....symbol GKI.

AMEX has no policy regarding the covering of short positions by BB market makers. They do not like the idea of a short position larger than the float by a multlple of 3x to 4x and recognize the market disruptions that could occur, but they currently have no policy that would require forced covering.

Delivery requests that require buy-in activity could cause disruptions but not a specific enforceable policy. This intepretation came directly from the AMEX.