OTCBB Transfer Comment

July 10, 2006 Ms. Nancy M. Morris Secretary Securities and Exchange Commission 100 F Street, NE Washington, DC 20549-9303 Subject: File No. SR-NASD-2006-039 Dear Ms. Morris, Pink Sheets LLC (“Pink Sheets”) strongly supports the NASD’s proposal to modify and expand NASD’s authority to initiate trading and quotation halts in over-the-counter (“OTC”) equity securities. However, we object to that portion of the proposal that would permit the NASD to impose a halt greater than four business days because the NASD’s rules fail to provide essential due process rights to interested persons that may be adversely affected by the trading halt. We also believe that with this protection added the proposal can be made much more effective through more often initiation of halts by the NASD as well as expanding the type of foreign halts recognized. Pink Sheets is the leading provider of pricing and financial information for the over-the-counter (OTC) securities markets and, among other things, operates an Internet-based, real-time quotation service for OTC equities and bonds for market makers and other registered broker-dealers. A trading halt that extends for a period greater than four days will cause the security to lose “piggy back eligibility” under Rule 15c2-11 of the Securities Exchange Act of 1934 (the “Exchange Act). This will require market makers in the security to file a Form 211 to resume trading, a process that frequently ...