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Robert Rickard Comment On Regulatory Notice 21-19

Robert Rickard
N/A

Thank you for your time. Currently as it stands, there is too little information in true short positions. With a market makers ability to create synthetic shares for “liquidity”, at some point the true positions need to be accounted for. If a bank, a market maker, and or other parties can hide positions through layered securities like CDOs or swaps, there is no benefit to the market, only the entities on the short side benefit. It doesn’t show a true borrow fee for short interest, and is already a sign of two entities working in tandem, possibly in collusion. As I understand it, when shares are counted for a shareholder meeting. A shrinking of the shares is done by the brokers. At what point should synthetic shares it be allowed to be created for liquidity for the price to go up? When these same entities have a shirt position on securities? 5% synthetic ? 50% ? It shouldn’t be too hard to get an audit on the shareholders side. Yet there seems to be no auditing per broker. If a security is trading many times the float over each day. That should be an indicator that there’s a big issue, and when a lot of those trades are fail to deliver, it makes a mockery of the market altogether. The current issue with dark pools being used for most retail out of nowhere, is just another form of collusion. If I made a short bet and the price went up, I would be margin called, I would need to eat my loss and try again. The same should be the case for any entity. There are a lot of things that need to be addressed with the market, more visibility with reporting and less allowance on fail to delivers is a good place to start.