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Paul Comment On Regulatory Notice 21-19


Of particular interest is the section on Synthetic Short Positions. It seems that approved participants can use synthetics to improve market liquidity, but it also creates a problem of diluting the stock when the shorts fail to deliver. Would position reporting also help to track FTD's better and implement some regulation to have those failures sufficiently resolved before more synthetics are allowed to be created? I understand this could squeeze the shorts a bit, but it seems to make sense in terms of correctly managing scalability.