Please comment if the following hypothetical transaction violates any SEC rule, Exchange/ECN rule or ethics. Premise: It is differcult to short NYSE stocks that are free-falling because of the down-tick rule. Possible Trading Solution: 1. Open 2 brokerage accounts. 2. When you want to short a NYSE stock on a downtick, use Brokerage Account #1 to initiate a short position. 3. Route Brokerage Account #1's Short Sell order to ISLD ECN and let it sit there on the Offer. 4. Use Brokerage Account #2 to buy the Short Sell order that you left on ISLD ECN 5. Turn around and hit NYSE bid with the Sell order from your Brokerage Account #2. (You don't violate the downtick rule because Brokerage Account #2 is Long on the stock) This in effect has a wash transaction on Brokerage Account #2 but you will have initiated short position on Brokerage Account #1 in spite of a downtick. What do you think ? Would this hypothetical transaction be considered as manipulation or unethical since part of this transcation requires you to buy and sell to yourself.