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Robert Andersen Comment On Regulatory Notice 21-19

Robert Andersen

First, there is no rule that can be put in place where the repurcussions are fines. Fines are a cost of doing business. Period. The street always makes far more money illegally then they pay in fines. 150% minimum fines. Now, that said, self reporting is a joke. We have the systems and technology available to ensure trades are marked correctly, that they are delivered adequately, not rehypothecated, and accurately reported. We should have 100% free, 100% accurate long vs short data on every stock, every day. Absolutely NO exemptions for any market participate, for any reason. Furthermore, dark pools should not be excluded in these demands. Every trade placed must be accounted for. Without this data, all the rest of the data in the market is completely worthless. We know now how inaccurate this data is and it's effect over the decades has been devastating to the REAL us economy. No investor can make an informed decision when we rely on self-reported, under-regulated, and under-enforced rules. The fraud that has been perpetrated should land several CEO's in prison. They get paid well enough to take that risk. If you take the job as CEO of a bank, get paid hundreds of millions per year in compensation, you do not get the opportunity to plead ignorance when your lending units are allowing naked shorting.