Chad Thomas Comment On Regulatory Notice 21-19
1. Require shares to be acquired before they can be sold. It is ridiculous that today shares are often not even located or are only located before actually being sold. Borrow the shares first, then sell them. 2. Better tracking of borrowed shares. It is ridiculous that shares can be leant out multiple times (often because they are only 'located' and not actually obtained before allowed to be shorted. 3. With todays technologies and API's there is zero reason to have delays in data.