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ElRojos Comment On Regulatory Notice 21-19


When reporting short interest can be skewed through a loophole, this needs to be addressed. When short sale restrictions are enacted as a safety for a volatile stock, but overridden through a mysterious, unregulated exchange: this needs to be addressed. When asset managing/ trading firms have access to order flow prior to retail investors, and can systematically alter a stocks natural and organic movement: this needs to be addressed. When ANYONE- exploits a loophole from placing a long call option and is labelled as long on the stock, but along the way intends to upset the current tracking algorithm placed by any short interest reporting organizations by vehemently, and fraudulently shorting a stock: this needs to be addressed When anyone disobeys, or is caught in an attempt to manipulate a price of any stock: this needs to be addressed. This needs harsher punishment, perhaps take a look at their profits within the quarter and penalize THIS amount. When an individual bravely speaks out against a company, you must protect them. This is a country with freedom of speech, and if there is evidence to support an individuals claim, it is your duty, and privilege to enforce an investigation. The length of time your organization takes to file and enact discrepancies has often been referred to as a slap on the wrist. Not sure how you can address this, but it is something to make note of. There should be additional filing obligations with the SEC when any trading organization wishes to short a stock more than 5% of it's total float in a single day. There needs to be a more firm way to track a short share. As it stands it is questionable where short shares are being delivered to and fro. Above all else, if any single company is shorted beyond, or even close to, the ENTIRE float and is still showing no evidence as to why they have not returned (or show no intention to!) the shares, this is viewed as an error. Not on the company that placed a stock in this predicament, but your organization. Someone needs to be held liable, and the issue lies at the top. How is it that an organization, contracted by the federal government, can so easily excuse, slap wrists, and ignore the CRIMES taking place, for decades- every single day, even- baffles me. The list is long, but I do believe your organization has the ability to stand up for all individuals who wish to invest healthily in any given stock. The term 'loophole' needs to be retired. Good luck, and thank you for reaching out to individuals who wish to see fair and just changes in the market