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Jay O. Comment On Regulatory Notice 21-19

Jay O.
N/A

1. All short sales must be reported to FINRA by the end of each settlement day and made public by the beginning of the next settlement day. - FINRA must automatically pull the information by market close electronically (i.e. NO self-reporting) 2. All unused loaned shares must be reported to FINRA by end of settlement day and made public by the beginning of the next settlement day - FINRA must automatically pull the information by market close electronically (i.e. NO self-reporting) 3. FINRA (or the SEC) shall *enforce* FTD (fail-to-deliver) purchases upon noncompliance within 2 settlement days. (T+2) 4. Lenders must be restricted from loaning shares to a potential borrower if the borrower has any outstanding FTDs within the same security. 5. All retail order flow MUST be routed through “lit” exchanges and settled by beginning of the next settlement day. 6. Payment for order flow (PFOF) must be banned, as it conflicts with a broker’s “promise” for “best” execution.