Stephen T Lee Comment On Regulatory Notice 21-19
As a RIA for over 20 yrs I have seen my fair share of shorting and have done it with some equities in special cases for aggressive clients. I am a small independent RIA that uses a combination of ETFs and individual stocks in the management of my clients funds. I can tell you flat out that the system of clearing and reporting short sales is completely broken. This is especially true with small, mid, and micro cap stocks. I have owned my firm for 10 yrs and will now no longer buy or hold any small cap stocks.....and instead just buy the index.