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Joe Clark Comment On Regulatory Notice 21-19

Joe Clark
N/A

The proposed amendment to FINRA 4560 is a laughable attempt at improving naked short selling internal control measures, actual regulatory action, or really any kind of further obligation on the part of the involved broker-dealers. There have been hundreds if not thousands of regulatory "actions" taken by FINRA related to short sale, and misreporting/misclassification of shorts. This filing appears to broaden the scope of required disclosures. period. end of filing. This does nothing to protect investors in a information landscape rife with inaccurate and unreliable information. Is the proposed disclosure an improvement on the already broken regulatory reporting regime? Yes. Does it actually do anything to limit or prevent further nefarious behavior, over-leveraging, or fraud? No it does not. Absolutely not. Your staff knows this. I find it insulting your organization believes this will have any material impact on the behavior of nefarious market participants, bad actors or opportunists. In short, Rule 4560 as written is inadequate. Additional penalties need to be put in place as an appropriate disincentive for undesirable and illicit activity in the financial markets, particularly amongst broker-dealers. I'm disappointed in this release.