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Marshall W Waters Comment On Regulatory Notice 21-19

Marshall W Waters

Having been a retail investor for over two decades, I only recently discovered the extent of market manipulation really going on behind the scenes. I applaud your organization's proposed changes. Specifically I believe the markets would benefit from public dissemination, in real time, the short positions, dark pool flow, and FTD's. I personally would go further, requiring a responsible person in the organization to certify, under penalty of perjury, that these numbers are correct, and modify your fine/penalty system so that the fines and penalties are commensurate with any "profit" made by these firms while violating the regulations. In summation, I believe your rules are a step in the right direction towards a transparent and fair market, but as usual, lack the teeth of any real enforcement, which is what has gotten us into this mess in the first place.