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Daron Sterling Comment On Regulatory Notice 21-19

Daron Sterling
N/A

First of all, stop pretending like Finra doesn't know how corrupt and rigged the Stock Market is especially given the fact that Finra facilitates and encourages such behavior at the expense of the retail investor. Yes, Finra facilitates and encourages such behavior contrary to the statements made on their "About" page which I will provide some examples as proof. 1) Fail-to-deliver Data: -Data is old and useless by the time the Investor sees it. The first half of a given month is available at the end of the month. The second half of a given month is available at about the 15th of the next month. -Data is not granular. Data omits one of the most important items - the firm(s) that have these FTD's. Values of total FTD shares represent the aggregate net balance of shares that failed as of a particular settlement date. 2) Lack of enforcement: -No guarantee that the accuracy of the data will be correct or up to date. -Firms are left to police themselves in respect to submitting correct data. -No Random surprise Audits conducted on any firms by Finra. 3) Fines and Punishments: -The fines that firms get for violating rules are pennies to them. -Firms consider fines as a "cost of doing business". I wouldnt be suprised if they write them off their taxes as a business expense. -Finra is actively encouraging market abuse with these "fines" that have little to no effect. -Finra should just call it a "fee" instead because payment comes with a "no addmission of guilt" and the ability to continue making the same violatons over and over again. 4) Dark Pools and Data: -Finra publishes dark pool data with a 14 day delay making it useless. -Dark pools are unregulated and ripe for abuse. -More then 50% of trades happen in the darkpool affecting Retail price discovery. -Retail not allowed to participate in Dark Pools -limiting the so-called "free market". As you can see Finra favors Firms and encourages bad behavior at the expense of the retail investor. From 2018-2020 Finra has spent $33.6m in "Market Surveillance Patterns and Reviews" that thinks 5.5m Fail-to-delivers in a single settlement date is normal. smh Finra claims to protect the investing public against fraud and bad practices. Yet the CEO is a lawyer and their Execs & Board of Governors consist of current and former employees of Hedgefunds, Banks, SEC, Federal Reserve etc. Finra is a self serving business disguised as a non-profit with the sole purpose of pushing the agenda of its puppet master. Given Finra Executive's background you actually expect the public to believe that it is just now coming up with the idea for potential enhancements to its short sale reporting program? It is all no brainer stuff that should have been implemented a long time ago. The only reason any rule changes are even being made/considered is because of what GameStop exposed back in January. Instead of dealing with the root of the [still ongoing] problem with the abusive amount of FTDs and price manipulation taking place in the dark pool, Finra waits 7 months to come back with some potential enhancements. Finra, you are so Fraudulent and people see right through it. -daron sterling