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Gabe Fineberg Comment On Regulatory Notice 21-19

Gabe Fineberg
N/A

What implementation period would be appropriate to provide members with sufficient time to make the systems changes necessary to comply with this requirement? Change needs to happen as soon as possible, immediately to restore faith in the markets. To make these crooked markets somewhat fair to retail investors. FINRA is considering whether daily or weekly short interest position reporting would be preferable. What are commenters’ views on the preferred frequency of short interest position reporting? Daily is the only fair option. We need to have information on what these institutions are doing in their wine caves. Are there any other short sale-related changes not discussed above that commenters recommend? Eliminate dark pools Fines should be greater than the profit hedge made from the illegal activity (Same as al white collar crime) Jail time is needed for market manipulation. No probation or small fines. Short positions should be forcibly closed out if illegal market manipulation is found and trading rights of those involved should be revoked. Shorting taking place in the dark pool needs to be disclosed to the public! If an institution buys shares in the dark pool and then dumps (sells) those same shares on the public exchanges to tank the price, this should have to be reported and it should be illegal. It's market manipulation. Fail to Delivers should be reported to the public as well as Finra. Short interest should not be self reported. There should be a system in place where short interest is automatically reported. This should be built into the markets and automatically reports this back to Finra. There should be audits done to check for shorts hidden in options whenever there is clear market manipulation.