Hello, As a full-time investment portfolio manager for the last 15 years, I feel like this entire filing is yet another moot point. No matter which valid point I bring up, the Commission will only find it invalid, however, here goes nothing: I respectfully advise the Commission to re-think the overall goal in respect to their job function. You're asking for comment on something very little know about, as the entire subject of short selling has been an area of concern for a very long time. Short sale reporting isn't the issue, as I'm sure the Commission is aware of. The issue is the unfair advantages that the market participants have over the retail trader, and who exploit these advantages on a daily basis for their own personal interests. The lack of transparency regarding the off-exchange venues is absurd. Europe took the correct step in putting a volume cap on the dark pools. However, that only lead to the utilization of Systematic Internalisers, which again, makes these filings pointless regarding short positions. The absurdity of the market share breakdown is ignored on a daily basis. Dark Pools are allowed to account for over 40% of daily market share, as "no lit exchange has more than 16% market share, based on publicly available information", as several filings have read from CBOE, NYSE, NYSE Arca, and many other exchanges who agree with this issue. What's being done about this? Absolutely nothing. You continue to allow the big players to sit and conspire against retail, all while calling it a free market. Let's not kid ourselves. 1. These "enhancements" will do absolutely nothing to the overall market, as it is fragmented by nature due to the carelessness of the SROs, as you're fully aware. The issue is accountability. There's absolutely none of it, and the public is learning just how bad it all really is. The FACAD is coming to an end, unless you do the following, and quickly: In a perfect world: 1. Require short positions be reported DAILY. 2. Make it MANDATORY that short sellers much purchase back their shares by X date. (no expiration on a short sale is absurd, and the key component of the fragmented market) 3. Put a volume cap on dark pools, and start holding these bad actors accountable, and get back the price discovery onto the lit exchanges. These bad actors were allowed to manipulate, lie, and cheat their way through the financial crisis of 08, and there was no accountability then, either. It's time to change. If the problem is simply a lack of understanding, please contact me. 4. Realize that the continued behavior that you incentivize by simply slapping a small fee and label it as "Justice" is destroying the market faster than any other means. Claims were made that "gamification" of the market was created by Robinhood and Webull in 2021. Let's not kid ourselves. The entire market is controlled by algorithms, and is by no means "free." More people are watching now than ever. Your call.
Anonymous-CD Comment On Regulatory Notice 21-19
Hello, As a full-time investment portfolio manager for the last 15 years, I feel like this entire filing is yet another moot point. No matter which valid point I bring up, the Commission will only find it invalid, however, here goes nothing: I respectfully advise the Commission to re-think the overall goal in respect to their job function. You're asking for comment on something very little know about, as the entire subject of short selling has been an area of concern for a very long time. Short sale reporting isn't the issue, as I'm sure the Commission is aware of. The issue is the unfair advantages that the market participants have over the retail trader, and who exploit these advantages on a daily basis for their own personal interests. The lack of transparency regarding the off-exchange venues is absurd. Europe took the correct step in putting a volume cap on the dark pools. However, that only lead to the utilization of Systematic Internalisers, which again, makes these filings pointless regarding short positions. The absurdity of the market share breakdown is ignored on a daily basis. Dark Pools are allowed to account for over 40% of daily market share, as "no lit exchange has more than 16% market share, based on publicly available information", as several filings have read from CBOE, NYSE, NYSE Arca, and many other exchanges who agree with this issue. What's being done about this? Absolutely nothing. You continue to allow the big players to sit and conspire against retail, all while calling it a free market. Let's not kid ourselves. 1. These "enhancements" will do absolutely nothing to the overall market, as it is fragmented by nature due to the carelessness of the SROs, as you're fully aware. The issue is accountability. There's absolutely none of it, and the public is learning just how bad it all really is. The FACAD is coming to an end, unless you do the following, and quickly: In a perfect world: 1. Require short positions be reported DAILY. 2. Make it MANDATORY that short sellers much purchase back their shares by X date. (no expiration on a short sale is absurd, and the key component of the fragmented market) 3. Put a volume cap on dark pools, and start holding these bad actors accountable, and get back the price discovery onto the lit exchanges. These bad actors were allowed to manipulate, lie, and cheat their way through the financial crisis of 08, and there was no accountability then, either. It's time to change. If the problem is simply a lack of understanding, please contact me. 4. Realize that the continued behavior that you incentivize by simply slapping a small fee and label it as "Justice" is destroying the market faster than any other means. Claims were made that "gamification" of the market was created by Robinhood and Webull in 2021. Let's not kid ourselves. The entire market is controlled by algorithms, and is by no means "free." More people are watching now than ever. Your call.