Benjamin Fehling Comment On Regulatory Notice 21-19
Shorting as a market practice is a ridiculous concept to begin with because in no other area of a capitalist market can you borrow something that is already owned and then sell it, only to buy it back at a lower price to intentionally profit off of the initial lender. That aside, self reporting clearly isn’t working, and the ability for borrowed stock to be mis-marked, intentionally or otherwise, is a long standing pervasive issue. Shares need a better marking system to denote “Borrowed” and “Sold while borrowed (shorted)” and a running tally until returned to the original lender. There’s various systems for this, like the Time to Live or hop count in Internet Packets for instance. All short data should be traceable, and reported in real time.