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Christopher Fisher Comment On Regulatory Notice 21-19


The short interest reports from ETF, Market makers, Pre Brokers, Hedge funds and all other investment institutions should be reported accurately and daily with failure to delivers and synthetic short positions covered in 2 business days. The penalties for FTD and mismarking long and short positions as well as short laddering and devaluing securities through high volume, high frequency dark pool trading must be stopped with dark pool trades having a regulatory "cool down" where they cannot simply place the same trade of shares back and forth between another hedge fund for a penny less each time 100,000 times until the stock is destroyed and the value so distorted that no one knows the true value of the stock for months on end. The penalties must be higher. Fines in the millions are simply fees and a subscription cost to the table for big funds and they pay them gladly because they are fractional to the profits they gain by way of these fraudulent and manipulative tactics. They must be suspended for days and weeks for these offences and it must be recorded and reckoned daily. The strength and freedom of all people is at stake and these monopolies must be broken up. The fines need to be punitive based on the total value of the fund and by percentage. Example if a fund were to be caught naked shorting and did not cover in 2 business days they would be suspended for 2 days from all market and dark pool activity. If they did it again, they are suspended for the whole trading week 5 days. If caught again the fine for the fund would be 10 percent of the total fund value at time of infraction. If they do it again the fine is 20 percent. Then 40, then 60. Then total liquidation. They should be operating with the highest fiduciary integrity not the lowest and shadiest. Individual registered reps would be destroyed for 3 major infractions with massive fines and jail time. Why is it different for major players?