John Kozubal Comment On Regulatory Notice 21-19
All FTD's should be reported daily and all self regulation should stop. All FTD's should be defined in a T1 and settled in a T2. All short positions should be identified publicly. All naked shorts should be excluded and settled with FTD settlements. All fines for violations should be on a per share basis. No more speeding tickets where the fine is cheaper than the position. Let the violators actually go to court or settle for massive fines. Self regulation rules should now be enforced by the regulating bodies.