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Christopher T Funakoshi Comment On Regulatory Notice 21-19

Christopher T Funakoshi
CPA (Non active)

Hi Yvonne Huber, and Racquel Russell About myself I am a typical retail investor who has just began studying for the FINRA exams. Concerns/ Suggestions: 1. Please reduce the buy back period for Market Makers to T-0 this is the standard for other countries. 2. Please make the Fee for missing out on the T-0 5% of the FMV of the current price of the share multiplied by the number of FTDs and charge them this fee daily. Until SEC Rule 613 CAT becomes implemented, please create a Waterdown version of it and have a 3rd party auditor review it. This will increase confidence in the marketplace, and put to sleep any claims of corruption/ naked shorting. 3. Reduce the amount of shorting to from 140% to 100%. 4. FTD should be seen as a liability to the market and FINRA as such there should be a fine for companies that have failed to deliver. I suggest a 5% fee of the current price of the share for each share that has failed to deliver and a daily fee .05% for each day after. Questions: How will these new rule changes affect the FINRA EXAMs will the new rules become a part of the exams immediately.