Bryan Greer Comment On Regulatory Notice 21-19
Short selling, as a tool was intended to hit back at corporations that were found to be cooking the books. Unfortunately, today it is a tool with nefarious intention with no regard for the impact it might have have on an otherwise good company, it's entire employee base and downstream jobs it involves itself in. As one who has managed portfolios and also invests privately it has never been more clear that banks and funds collaborate to impact fair value in their favor. If the investment field is ever going to be fair... If the US Stock market is ever going to be trusted... things must change so that 100% of all investment decisions are based on equal, and 100% transparent data between all entities, individual to corporate. As this comment request applies to short interest I will address it, but it is just one step forward in the pursuit of a fair market; 1. Short sales must be reported daily and released the following morning for public view 2. Naked, synth or rehypoth shares must be reported separate, under the same time frame and have a T+2 day window to be closed out 3. Shorts must be absolutley "Borrowed", not "located" 4. Shorts can not be offset or refreshed in any LIT, UNLIT exchange nor be hidden in the options chain. 5. All shorts selling, covering and activity otherwise must flow through the LIT exchange where the stock resides. 6. Eventually, 100% elimination of naked shares. 7. Fines for those who violate and new rules surrounding short selling should be greater than the reward, or potential reward of the trade. Even, and if necessary it should include the pulling of all trading privilege by permits and/or licensing and liquidated out of business. Unfortunately we live in a time of greed and manipulation. As long as we are going to allow financial manipulation by software there is no excuse for any delay in data and the discovery of manipulation. The rest of the world markets are way ahead in the pursuit of fairer trading and FINRA doesn't really need "comment" to do it's part in reestablishing integrity into the US Stock Market(s).