Roderick Murphy Comment On Regulatory Notice 21-19
Hi Some considerations Shorting should only be allowed if the Stock has been pre-located , will an audit trail and consent of loan from Holder , not just custodian . If Shares are electronic they should should have a marker that will only allow them to be Loaned / Shorted against max 1 times. other wise if marker reflects share is already oan it wont be eligible. This makes a good motivation to move to an NFT like or Blockchain type basis for shares. Short reporting should be daily.