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Philip Bennett Comment On Regulatory Notice 21-19

Philip Bennett

Shorting is common practice within the securities market and usually helps balance prices of securities relative to the value of the security & the speed at which they've grown. There is nothing wrong with shorting, however there is a huge problem when certain stocks and securities have over 100 percent of outstanding shares shorted. This is mathematically impossible with the only conclusion to this occurrence leading to more shares being borrowed than the entire amount of outstanding shares. This is where we need changes. We also need more transparency with dark pool data (frankly dark pools shouldn't be allowed, institutions should not have their own markets where they can buy shares in the pool, then sell / dump the shares on the retail market leading to selling pressure on securities for retail traders) since the price of securities like AMC holdings seems to be largely affected by dark pool trading. They seem to be correlated since short interest on AMC has rose significantly in the last several weeks, even with approximately 80% of the outstanding shares being held by retail investors, with a continuous number of available shares to buy (aprox. 80-90 million free float shares).