Denis Blois Comment On Regulatory Notice 21-19
In regards for comments on 21-19 regarding short positions, here are my thoughts. * Every share should be tracked with unique identifier and should have the ability to be marked as lent out, unassigned/free, owned-lendable, or owned-not-lendable and be registered with a single central database to prevent duplication/ falsification of data. The ability to mark a share as owned-not-lendable shall only be set by the entity owning the shares and not by market makers and shall only be removed upon that share being sold or changed by the share owner.