re: Comment on Short Interest Position Reporting Enhancements and Other Changes Related to Short Sale Reporting To whom it may concern, the current structure and function of the American Equities Markets has, over a period of many years (& now on display for the whole world to see in the unfolding of the Meme Stock Scandal), been utilized to swindle trillions of dollars from The American Retail Investor. The subsequent damage to the integrity and reputation of the market is immeasurable. Speaking for myself, if nothing is done about this, I, & assuredly many, many, many others will NEVER have faith in the American Equities Markets EVER again. Therefore, I recommend the following actions be taken to restore integrity to the markets: 1. DELETE Dark Pool Trading- I have heard the arguments on behalf of keeping the Dark Pools for the purpose of maintaining liquidity in case of some sort of Black Swan Event. However, Market Makers have not shown themselves trustworthy of this privilege. The original intent of these Dark Pools was to minimize price fluctuations during said Black Swan Event & not a way to manipulate price. Let’s look at the example of the equity with ticker symbol AMC on 7/22/21. On this day at 12:18pm the Dark Pool had accounted for 91% of the days trading with the end of day total being over 70%. Because so much of this info is unknown to retail, the only assumption is this was the equity buy orders being manipulated to control the price of the equity. Please look back through the history of 2021 where Dark Pool volumes steadily increased since January. This is a disgraceful use of a privileges granted to Clearinghouses, Market Makers and Brokers to protect retail, not against it. 2. DELETE Market Makers (or any other player’s) ability to create synthetic shares to “aid” market liquidity. This privilege is another that has been abused to the detriment of the Retail Investor. After many months of high volume trading on the open exchanges since February 2021 the total float of AMC has been traded over 20 times with blatantly incongruent price action on the equity. Anyone with the slightest bit of knowledge regarding supply and demand would not that does NOT compute. 3. REQUIRE ALL TRANSACTIONS BE SETTLED BY END OF THE BUSINESS DAY. Enough of the market order delays & the high frequency trading of synthetic shares both used as weapons against the retail investor. a. PROHIBITION of the trading of synthetic shares as mentioned in the above comment on ladder attacks. b. PROHIBITION of Market Order delays PERIOD. I keep referring back to AMC as I have watched it very closely since February 5, 2021 & have witnessed with my own eyes the chicanery perpetrated against The American Retail Investor. Even a person with the most rudimentary knowledge of the law of supply and demand know that days with high volumes of buy orders should have INCREASING price action not decreasing as we have seen on many, many, many days with AMC. c. IMPLEMENT BLOCKCHAIN DIGITAL CERTIFICATION (or other verifiable technology) OF EACH INDIVIDUAL SHARE TRADED ON ANY EXCHANGE governed under the guidance of FINRA &/or The SEC. I’m sick of my money being put to sleep by bad actors in the “noble” guise of keeping liquid markets while operating under nefariously archaic rules legislated for The Victorian era. 4. PROHIBITION OF DERIVATIVE (Call/Put) SWAPS – Again, why must we sit here knowing the number of Failure to Delivers on AMC and other equities continues to increase but were able to be swept under the rug with a package deal to provider shielding of the most egregious offenders. ENOUGH ENOUGH ENOUGH THE AMERICAN RETAIL INVESTOR NEEDES PROTECTION FROM NEFARIOUS ACTORS IN THE MARKET! IF THE REGULATORY AGENCIES WON’T DO IT WHO WILL???
Gerard DeLeo Comment On Regulatory Notice 21-19
re: Comment on Short Interest Position Reporting Enhancements and Other Changes Related to Short Sale Reporting To whom it may concern, the current structure and function of the American Equities Markets has, over a period of many years (& now on display for the whole world to see in the unfolding of the Meme Stock Scandal), been utilized to swindle trillions of dollars from The American Retail Investor. The subsequent damage to the integrity and reputation of the market is immeasurable. Speaking for myself, if nothing is done about this, I, & assuredly many, many, many others will NEVER have faith in the American Equities Markets EVER again. Therefore, I recommend the following actions be taken to restore integrity to the markets: 1. DELETE Dark Pool Trading- I have heard the arguments on behalf of keeping the Dark Pools for the purpose of maintaining liquidity in case of some sort of Black Swan Event. However, Market Makers have not shown themselves trustworthy of this privilege. The original intent of these Dark Pools was to minimize price fluctuations during said Black Swan Event & not a way to manipulate price. Let’s look at the example of the equity with ticker symbol AMC on 7/22/21. On this day at 12:18pm the Dark Pool had accounted for 91% of the days trading with the end of day total being over 70%. Because so much of this info is unknown to retail, the only assumption is this was the equity buy orders being manipulated to control the price of the equity. Please look back through the history of 2021 where Dark Pool volumes steadily increased since January. This is a disgraceful use of a privileges granted to Clearinghouses, Market Makers and Brokers to protect retail, not against it. 2. DELETE Market Makers (or any other player’s) ability to create synthetic shares to “aid” market liquidity. This privilege is another that has been abused to the detriment of the Retail Investor. After many months of high volume trading on the open exchanges since February 2021 the total float of AMC has been traded over 20 times with blatantly incongruent price action on the equity. Anyone with the slightest bit of knowledge regarding supply and demand would not that does NOT compute. 3. REQUIRE ALL TRANSACTIONS BE SETTLED BY END OF THE BUSINESS DAY. Enough of the market order delays & the high frequency trading of synthetic shares both used as weapons against the retail investor. a. PROHIBITION of the trading of synthetic shares as mentioned in the above comment on ladder attacks. b. PROHIBITION of Market Order delays PERIOD. I keep referring back to AMC as I have watched it very closely since February 5, 2021 & have witnessed with my own eyes the chicanery perpetrated against The American Retail Investor. Even a person with the most rudimentary knowledge of the law of supply and demand know that days with high volumes of buy orders should have INCREASING price action not decreasing as we have seen on many, many, many days with AMC. c. IMPLEMENT BLOCKCHAIN DIGITAL CERTIFICATION (or other verifiable technology) OF EACH INDIVIDUAL SHARE TRADED ON ANY EXCHANGE governed under the guidance of FINRA &/or The SEC. I’m sick of my money being put to sleep by bad actors in the “noble” guise of keeping liquid markets while operating under nefariously archaic rules legislated for The Victorian era. 4. PROHIBITION OF DERIVATIVE (Call/Put) SWAPS – Again, why must we sit here knowing the number of Failure to Delivers on AMC and other equities continues to increase but were able to be swept under the rug with a package deal to provider shielding of the most egregious offenders. ENOUGH ENOUGH ENOUGH THE AMERICAN RETAIL INVESTOR NEEDES PROTECTION FROM NEFARIOUS ACTORS IN THE MARKET! IF THE REGULATORY AGENCIES WON’T DO IT WHO WILL???