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Neil Robertson Comment On Regulatory Notice 21-19

Neil Robertson

Short positions should be force closed on failure to deliver. The ability to cover a failed delivery with options or collateral does not excuse that an investor is actually stolen from with a failure to deliver. Also of concern, the "can kicking" through synthetic share production by means of options contracts. No one should be allowed to have 400 million put contracts on the books. Is this not the same as saying they are purchasing the right to sell 4 billion shares? What if that number of shares doesn't exist for the company? How is there not oversight of this? Final point: failure to deliver (FTD) needs to forcefully close their position at market value or higher. No covering. Stealing should never be allowed in fair market practices. How can someone logically state that stealing X shares from investors is alright because they posted X cost collateral to the intermediates. Did the person purchasing the item receive it? No. It was failed to deliver, they must find the item immediately or we have a broken system. I can't xerox a car title and sell it to you then keep telling you I will find it later "I promise." You will tell me to kick rocks and deliver the car you bought.