Hello FINRA, First, off thank you allowing public comment on the need to better regulate options and trades involving short positions and shorting instruments. Please let ask a simple question: If Failure to Delivers on the Threshold list can be satisfied with borrowed shares, who is the owner of the settled delivery? Why have a Threshold list at all if it is ignored when the settlement period is treated like Paul, whom just got paid with Peter's robbed shares? I heartedly endorse all the changes proposed to the FINRA for rule 21-19. As a US born citizen who has come to understand the stock market as a retail investor, I'd like to say these rules changes are a glimmer of hope for more transparency with much needed disclosures. I admit that the market is viewed broadly as rigged in favor of those entities such as market makers, hedge funds, and indeed many brokers who view the law as nothing more than a body for which fines are simply fees and insider trading is so commonplace that the concept of rules against are treated as a joke. This pay to play structure and lack of substantial enforcement degrades confidence in a cornerstone of our broad US economy. It's no secret among traders how synthetic short positions and creation of shares 'not delivered' takes away the fundamental operation of the market - the concept of scarcity. Where market makers create liquidity to allow for retail trades without locating shares, and eventually deliver only a promise rather than a share than can be located, our whole financial system is placed at enormous risk. Please implement and enforce the regulations put forth under this rule as soon as possible. Thank you and Best Regards, Justin San Diego, CA
Justin Comment On Regulatory Notice 21-19
Hello FINRA, First, off thank you allowing public comment on the need to better regulate options and trades involving short positions and shorting instruments. Please let ask a simple question: If Failure to Delivers on the Threshold list can be satisfied with borrowed shares, who is the owner of the settled delivery? Why have a Threshold list at all if it is ignored when the settlement period is treated like Paul, whom just got paid with Peter's robbed shares? I heartedly endorse all the changes proposed to the FINRA for rule 21-19. As a US born citizen who has come to understand the stock market as a retail investor, I'd like to say these rules changes are a glimmer of hope for more transparency with much needed disclosures. I admit that the market is viewed broadly as rigged in favor of those entities such as market makers, hedge funds, and indeed many brokers who view the law as nothing more than a body for which fines are simply fees and insider trading is so commonplace that the concept of rules against are treated as a joke. This pay to play structure and lack of substantial enforcement degrades confidence in a cornerstone of our broad US economy. It's no secret among traders how synthetic short positions and creation of shares 'not delivered' takes away the fundamental operation of the market - the concept of scarcity. Where market makers create liquidity to allow for retail trades without locating shares, and eventually deliver only a promise rather than a share than can be located, our whole financial system is placed at enormous risk. Please implement and enforce the regulations put forth under this rule as soon as possible. Thank you and Best Regards, Justin San Diego, CA