SIFMA provides comments to the Securities and Exchange Commission (SEC) on proposed anti-fraud rule, proposed Rule 10b-21, Release No. 34-57511; File Number S7-08-08.  SIFMA strongly supports the SEC’s stated goals of addressing potentially abusive “naked short selling” practices; and attempts to address and prevent manipulative trading activity.  SIFMA shares concerns that enactment of a new anti-fraud rule might have unintended consequences. SIFMA believes that having the SEC act upon the proposed amendments to the 1994 Prime Broker No-Action Letter would be a better approach to addressing concerns about sellers engaging, or attempting to engage, in naked short selling through misrepresenting information.