Cortney Comment On Regulatory Notice 21-19
To whom it may concern: I would like to know if there are plans to repair the fines in regards to short interest reporting, naked shorts and dark pool trading? I think that naked shorts should be fined based on the quantity of fake shares multiplied by the price of the share in question. So for 5 million fake shares at say $25 per share would result in a $125 million fine. This is a fair way, since you are penalizing the guilty party by making them pay the cost of each fake share that was created.