Ashley G. Comment On Regulatory Notice 21-19
I request the following to be taken into consideration for addition to the proposed rule change: - Short positions held by market makers should require enhanced reporting. In addition, anytime an options contract is opened by a MM well below market value for the stock, the time of trade and involved party should be reported. - Incorporate ETF short interest in reporting requirements. - Require firms to maintain securities lending records for 10 years. - Fines for naked short selling should equal the profit of the cumulative short position with a portion payable to the victimized Company.