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Paul Carmon Comment On Regulatory Notice 21-19

Paul Carmon

Proposals look great and I'm in agreement with all as they stand. Further comments: There's no reason why in a fast digital age reporting can't be daily, providing the most up to date information to everyone. Addition of synthetic shorts is a very welcome one. Further, there is speculation derivatives can be used in a way to make it appear a long position has been taken to cover a short position when in reality that long position is cancelled out by a derivative with a future expectation date. Effectively hiding the short position. If someone could be added to account for the derivative too in order to close that loophole that would be fantastic.