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Ian Comment On Regulatory Notice 21-19


Digital data doesn't require days to locate. Short interest and FTD data is able to and should be reported daily. The varying T+ cycles have proven to work in the favor of Funds that make their money shorting companies out of existence, by allowing them to be wildly over-leveraged in their positions and also creating opportunity to take advantage of methods like naked short selling. If the data isn't reported, the market price isn't accurate. The rules are an illusion and the fines are effectively a small fee to pay to be able to abuse the market in these manners. A fair market needs more transparency.