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Ken Tatis Comment On Regulatory Notice 21-19

Ken Tatis
Systems Engineer

ENFORCE YOUR RULES. These rules don't mean anything if they're not enforced. And I'm not talking about giving Robinhood a 70m lawsuit, that's just the cost of doing business. The penalties need to be crippling to ensure that the rules are followed. Reduce the reporting period to daily. We live in the digital age, there is absolutely NO reason that this information isn't reported either immediately or at the close of business. Anything else is just an excuse to allow market manipulators to distort numbers and misinform. Get rid of dark pools... Why is that even a thing??? Everyone should be participating in the open market. Not buying in the dark pool and selling in the exchange to bring the price down. Require that exchanges report failures to deliver and naked shorts alongside covered shorts. Reduce the holding period for reported days from 4 days to 2 or fewer. Document and release the identities of funds that have open short positions and their sizes. This would operate similarly to the way longs and options are currently reported. Regularly audit the reported positions to ensure the self reporting is accurate and fine (or penalize) entities that misreport. This would include going deep to ensure that no shorts are being hidden in long options contracts, or mislabeled as long positions.