Rocque Sandoval Comment On Regulatory Notice 21-19
Short sale reporting should require actual shares to be in their position to short. Reporting should consolidate every trading day to ensure there is only 100% of the float in circulation. Naked shorting should be a fine at a 15% of the firms last year revenue earned. In addition repeat violations should increase in 30% to impact the firms overall bottom line to ensure it is not the cost of doing business that exist today. Shares should also be located within 48 hours and failure should result in meaningful fines. Shorting should not exist in my opinion, but if it's going to then their needs to be checks and balan es in place to protect retail customers and companies.