Skip to main content

Mililani Comment On Regulatory Notice 21-19

Mililani
N/A

As it stands, I see no reason why any of the bad actors will accurately mark or report their positions. Even with a condensed reporting timeline, there is no vehicle for FINRA to keep track of mismarked/illegal/synthetic/etc. short positions. Recommend that stocks released by companies should have tracking numbers so that short positions shall be required to have a one for one trace via tracking number to an actual position. Either this, or use publicly accessible blockchain technology to trace long and short positions. Please disallow synthetic positions via married options and create a hard path to fulfilling fail to delivers within the guidance timeline instead of allowing pushing them down the road forever. Separately, there is no reason for bad actors to adhere or care about any new rules if there are no serious repercussions. If found out, the punishment should fit the crime. We need to move away from fines to imprisonment, freezing the trading of bad actors, and the forfeiture of ill gotten gains by market manipulation in its entirety. It is troubling that a common thief would be imprisoned, but the wall street thieves are immune while the impact of their actions amount to billions to trillions of dollars, impacting and ruining millions of lives as opposed to the common thief who has relatively little impact in comparison.