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Frank Brown Comment On Regulatory Notice 21-19

Frank Brown

FINRA should immediately move to require daily short interest reports. More and better information will allow for better price discovery, which is the whole point of markets. FINRA should also consider making rules that punish those who commit FTDs (Failure to Deliver). Market Makers should have their naked short selling exemptions removed or severely limited. Finally, FINRA should move to require real time settlement, or T+0. The current settlement period of 2 days has been shown to increase risk for both brokers and the DTCC.