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Anonymous-RP Comment On Regulatory Notice 21-19


I appreciate many of the actions that are listed. Requiring funds to post their short positions (whether synthetic or other) should absolutely be mandatory. The lack of transparency only creates opportunities for these funds to create illusionary positions and to skirt regulatory requirements. The greater the transparency these funds are required to maintain the greater the benefit to both regulatory bodies and individual investors. The only real issue that carries on regardless of any proposed changes is accountability. There are currently barely existent operations in terms of recourse. Any form of punishment that exists currently carries absolutely no incentive for funds to comply. Any changes to reporting must include a noticeable increase in fees associated with disregarding these reporting requirements. An excellent example was set by regulators in South Korea who recently made the fines surrounding synthetic/naked shorting/FTDs to appropriately reflect the profits that are made from these actions. As with many individual investors, I have lost a great deal of faith in the regulators within this industry. Without actions to start holding these corrupt funds accountable these issues will continue. I do believe the increased reporting is an excellent step forward but without a sharp and strong increase in punishment for ignoring these motions I don't see these changes having any real world effects.