John Kozubal Comment On Regulatory Notice 21-19
All FTD's should be reported daily and all self regulation should stop. All FTD's should be defined in a T1 and settled in a T2. All short positions should be identified publicly. All naked shorts should be excluded and settled with FTD settlements. All fines for violations should be on a per share basis. No more speeding tickets where the fine is cheaper than the position. Let the violators actually go to court or settle for massive fines. Self regulation rules should now be enforced by the regulating bodies. There is nobody adhering to self regulation in anyway, nor is there any good faith in the common investor for the self regulating institutions. No retail trades should be routed to dark pools, in bulk or otherwise. All dark pools should be regulated and route observed. There is no way that a stock should have 40% small order flow and have 67% of total flow in the dark pool. Abolish payment for order flow. The guy that invented it killed himself in jail for the largest Ponzi scheme. Break up the market maker monopoly. Hedge funds should no be able to make their own market. No brokerage should be able to turn off trades, for any reason. This is why we have a SEC they if they have to should step in and run the brokerage until accounts are settled. There is "to big to fail" to big always fails.