Jerry Logan Comment On Regulatory Notice 21-19
Per your request for Regulatory Notice 21-19 regarding Short Positions, please find my comment below. The current requirements for short sale reporting, thorough as they may seem, are woefully inadequate in terms of depth, clarity and public transparency. I'd like to take the time to address what I see as issues that clearly and with immediate care must be addressed when considering short sales, market makers, hedge funds, and legal institutions tapped to enforce laws that clearly have no teeth in terms of punishment or enforcement.