Chad Thomas Comment On Regulatory Notice 21-19
1. Require shares to be acquired before they can be sold. It is ridiculous that today shares are often not even located or are only located before actually being sold. Borrow the shares first, then sell them. 2. Better tracking of borrowed shares. It is ridiculous that shares can be leant out multiple times (often because they are only 'located' and not actually obtained before allowed to be shorted. 3. With todays technologies and API's there is zero reason to have delays in data. Utilize integrations for real time reporting and ensure multiple Clearing agencies are not locating the same shares and lending them for sale without acquiring them. 4. Require daily short position reporting as public information. 2 week old data is not valuable. 5. Require real time integration of reported positions and hold accountable institutions for ACCURATE reporting. Short positions being 'accidentally' reported as long is unacceptable and yet happens all the time with no penalty. 6. Stop letting institutions self report! Audit them and make the penalties harsher than the profits they make by breaking the law! If I commit tax fraud or insurance fraud I go to prison. Institutions commit securities fraud falsely reporting data or failing to report, defrauding investors of billions and get a slap on the wrist fine that doesn't even put a dent in profits. 7. Do not allow High Frequency Trading Algorithm's. These are not tools that encourage investment, they are literally just playing the spread both ways to trim off the top. If I create an algorithm to trim off the top of deposits and withdrawals in order to collect extra pennies I go to jail for stealing that money. This is exactly the same thing they are doing. HFT's used to drive price down in order to encourage selling, then buy in to it and drive price back up turns the Market in to nothing more than a casino.