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2021070962701 Ronald J. Giovino, Jr. CRD 2236071 AWC va (2021-1628382016450).pdf

FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2021070962701 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Ronald J. Giovino, Jr. (Respondent) Investment Company Products/Variable Contracts Principal (IP) Investment Company Products and Variable Contracts Products Representative CRD No. 2236071 Pursuant to FINRA Rule 9216, Respondent Ronald J. Giovino, Jr. submits this Letter of Acceptance, Waiver, and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.

Victor Martinez Comment On Regulatory Notice 21-19

1. All shorts shall be reported to FINRA by end of each settlement day. 2. All unused loaned shares shall be reported to FINRA by end of the settlement day. 3. FINRA shall make public the outstanding unused loaned share(s) by end of the settlement day of a trading week. 4. All threshold securities sho regulation shall be reported daily with a full accounting of fail to deliver end by end of settlement day. 5. FINRA shall enforce FTD purchase upon noncompliance within 2 settlement days.

Anthony Vella Comment On Regulatory Notice 21-19

I would like to know when a stock has more volume for inflow compared to outflow, how does the share price still keep going down? Additionally, When a stock has a "ladder attack" to it, where is the SEC to step in and stop any manipulation? It is not understandable that a hedge fund company can use naked shorts, which everyone knows exists, yet nothing it done to combat the practice.

Kenneth Fleming Comment On Regulatory Notice 21-19

-Short positions should be reported on 13F's just like any other positions. -13F's should be updated daily. -Huge penalties for breaking the rules should be strictly enforced. The penalty should be at least double whatever the institution made from breaking the rule. If you continue to fine at an insignificant rate compared to the gains achieved by breaking the rules you are simply taking a cut of the illicit activity. The punishment must fit the crime to be an effective deterrent.