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Nicolas Benham Comment On Regulatory Notice 21-19

Nicolas Benham

Simplistic answer. Get all the information and in the shortest time frames, ex: in t+1. Consumers make purchases/sales for products based on reviews and the history of reviews. Why would a security be any different? You wouldn't want to transact anything if you had only a small % of information and come to find out 35 days later that the place you transacted with isn't dealing with its legal processes. When there is opportunity to be informed in a faster time frame with relevant data that exceeds what is currently provided, it should be taken. Anonymity is fine, so long as the regulatory system knows who is doing what and when with a how on a publicly traded exchange where millions can participate. Enforcement of the laws should be given priority, if high frequency transactions can take place... So can its tracking and dissemination. Otherwise it's all for naught since it can be altered for later. So yes, requirements for faster reporting, yes requirements for more information, yes for better transparency in a securities market, yes for tighter requirements for FTD, yes for T+1, yes for all of it. A bit of sarcasm within the example: Please hold One moment... I will go and apply for a loan, wait about 5 minutes for my credit history to be pulled. The example being that in 5 minutes, is excruciating detail of what I've done for the past 7 years can be reviewed and decided upon, but I need to wait 2 weeks for partial and self-reported information for a ticker where "misinformation" or "mismarked" transactions numbering in the hundreds of thousands can be covered up for 6 months... Ironically backwards. Next time till just self report I have x% of debt and never missed a payment, ah right... I'm not a large corporation where I can Fail to Deliver what was ordered. If I do that, I get essentially fined, sanctioned, and indebted with requirements to repay or have a chopped up history for the next 7 years.