Thank you for this opportunity to allow the people’s voices to be heard. With the intent to create more transparency within the market I submit the following rules to be implemented immediately: Rule 1. All short sales shall be reported to FINRA by end of each settlement day. Rule 2. FINRA shall make public report the day to day short sale by end of settlement day. Rule 3. All unused loaned shares shall be reported to FINRA by end of settlement day. Rule 4. FINRA shall make public the outstanding unused loaned share by end of settlement day. Rule 5. All threshold securities SHO Regulation shall be reported daily with full accounting of Failure to Deliver (FTD) by end of settlement day. Rule 6. FINRA shall enforce FTD purchase upon noncompliance with 2 settlement days. Rule 7: Upon evidence that any existing FTD has been rectified, no securities broker/vendors shall provide additional securities by means of loan, borrow, or lending. Rule 8: All retail order flow that goes through Dark Pool (DP) and/or unregulated channels shall be marked DP-sell and DP-buy Rule 9: Any Prime Broker, Hedge Fund, Market Maker (MM), and/or any other type of Broker that is subject to Investigation of Recovery of True Positions, has to cover all Positions Immediately
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Paul Pritchard Comment On Regulatory Notice 21-19
Thank you for this opportunity to allow the people’s voices to be heard. With the intent to create more transparency within the market I submit the following rules to be implemented immediately: Rule 1. All short sales shall be reported to FINRA by end of each settlement day. Rule 2. FINRA shall make public report the day to day short sale by end of settlement day. Rule 3. All unused loaned shares shall be reported to FINRA by end of settlement day. Rule 4. FINRA shall make public the outstanding unused loaned share by end of settlement day. Rule 5. All threshold securities SHO Regulation shall be reported daily with full accounting of Failure to Deliver (FTD) by end of settlement day. Rule 6. FINRA shall enforce FTD purchase upon noncompliance with 2 settlement days. Rule 7: Upon evidence that any existing FTD has been rectified, no securities broker/vendors shall provide additional securities by means of loan, borrow, or lending. Rule 8: All retail order flow that goes through Dark Pool (DP) and/or unregulated channels shall be marked DP-sell and DP-buy Rule 9: Any Prime Broker, Hedge Fund, Market Maker (MM), and/or any other type of Broker that is subject to Investigation of Recovery of True Positions, has to cover all Positions Immediately