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Ben Roberts Comment On Regulatory Notice 21-19

Ben Roberts

I'm afraid these changes do not go nearly far enough. While additional and more timely information is certainly appreciated, I believe what we need is for all short sales to be reported similar to the availability of Level II data. That is, every short sale should have to be recorded and immediately posted with the loan terms, where the shares were loaned from, and through which market it was processed. I also believe that the identity of the fund or the broker should be disclosed. By making the entire practice totally transparent it will mean that all eyes will be able to see and point out suspicious behaviors.