I fully support this proposed rule change and additional rule regarding short position reporting. Additional rules to protect investors, especially retail investors, should be explored on this topic as well as other issues such as order flow prioritization, block share lending, and ability to dictate exchanges for orders to be sent to. How is it possible for >50% of the daily trading volume to be done on private exchanges with no price reporting? How can these exchanges limit who is eligible to participate on them? How do you ensure investors purchasing on (for example) the NYSE that the bid/ask prices are accurate? How can investors be protected when their shares can be lent and resold multiple times? The market deserves to know the location and disposition of all authorized shares in real-time and across all exchanges. This will allow everyone, including margin lenders, know the total number of short positions and accurately assess risk based on real-time data.
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Bennet Comment On Regulatory Notice 21-19
I fully support this proposed rule change and additional rule regarding short position reporting. Additional rules to protect investors, especially retail investors, should be explored on this topic as well as other issues such as order flow prioritization, block share lending, and ability to dictate exchanges for orders to be sent to. How is it possible for >50% of the daily trading volume to be done on private exchanges with no price reporting? How can these exchanges limit who is eligible to participate on them? How do you ensure investors purchasing on (for example) the NYSE that the bid/ask prices are accurate? How can investors be protected when their shares can be lent and resold multiple times? The market deserves to know the location and disposition of all authorized shares in real-time and across all exchanges. This will allow everyone, including margin lenders, know the total number of short positions and accurately assess risk based on real-time data.