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Mike Comment On Regulatory Notice 21-19

Mike
N/A

Eliminate dark pools Fines should be greater than the profit hedge made from the illegal activity Jail time is needed for market manipulation. Short positions should be forcibly closed out if illegal market manipulation is found and trading rights of those involved should be revoked. Shorting taking place in the dark pool needs to be disclosed to the public. If an institution buys shares in the dark pool and then dumps (sells) those same shares on the public exchanges to tank the price, this should have to be reported. Fail to Delivers should be reported to the public as well as Finra. Short interest should not be self reported. There should be a system in place where short interest is automatically reported. Perhaps a computer system could be designed that tracks when a security is shorted and covered and automatically reports this back to Finra. There should be audits done to check for shorts hidden in options. *Each individual stock share should have a unique identifier attached to it. It should be publicly reported when institutions are margin called and when they close out their short positions. Require reporting of synthetic short positions. Reduce the reporting time on short interest. Require more frequent reporting of short interest data. Reporting would be required daily or weekly. SI reporting is currently only required twice monthy. Publish short interest data on their website of both OTC and exchange-listed securities. Require firms to list shorts hidden in options as synthetic short positions. List securities that are on the Threshold Securities List on their website along with other short interest data. Report Fail-To-Delivers to FINRA