I would like Finra to adopt the following measures. 1. Report every time a share is lent and create a tracking system so the same share cannot be lent more than once. 2. Force the RegSho requirements of FTD to attach to the stock/obligation so the T+35 is not reset through measures such as swaps or other derivatives trading. 3. Eliminate Naked Shorting in all circumstances. 4. Adopt fines in excess of 150% for the first and second offense of fail to delivers by T+35 for the Market maker and broker of the purchaser. 5. Suspend the trading license of any Market Maker and brokers for a third offense.
Joshua Walker Comment On Regulatory Notice 21-19
I would like Finra to adopt the following measures. 1. Report every time a share is lent and create a tracking system so the same share cannot be lent more than once. 2. Force the RegSho requirements of FTD to attach to the stock/obligation so the T+35 is not reset through measures such as swaps or other derivatives trading. 3. Eliminate Naked Shorting in all circumstances. 4. Adopt fines in excess of 150% for the first and second offense of fail to delivers by T+35 for the Market maker and broker of the purchaser. 5. Suspend the trading license of any Market Maker and brokers for a third offense.