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Phillip Banky Comment On Regulatory Notice 21-19

Phillip Banky
DoD

This is my first and most sincere comment to FINRA guidance and rulings Throughout my last few years of investing and last year of seriously understanding the markets -- there is no doubt in my mind that the framework of reporting and filling short positions on stocks is absolutely the most murky and shark infested water in the entire market. The reporting framework and the amount of loopholes from deep ITM calls, FTD rollovers and married options is absolutely shameful and furthermore puts regular retail investors and those who do not have extensive access to market tools like hedge funds and large banks (a.k.a. the "Expert" market) The system of short positions MUST be overhauled and needs to be tracked more closely, for a stock to be shorted over 100% of the float, and then tell companies they are not allowed to speak directly and then also tell hedge funds they are not obligated to report their shorts in the maximum amount of detail is a recipe for disaster where greed is commonplace. I don't think I need to comment - but feel obligated to in an official statement about how market makers whom are allowed to roam freely here in the USA have been banned in other countries for predatory shorting and how many other countries have noticed the harm to markets this brings and have since banned the extensive use of it and players who failed to abide by those rules they've set. The market is littered with margins that are not relative to liquidity these institutions carry and put our market in a very dark place. We have a major issue at hand and it must be addressed. Thank you. Please pass this and clean up the shorting market or we will be destined to fail this cycle again and again.