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Roderick Murphy Comment On Regulatory Notice 21-19

Roderick Murphy

Hi Some considerations Shorting should only be allowed if the Stock has been pre-located , will an audit trail and consent of loan from Holder , not just custodian . If Shares are electronic they should should have a marker that will only allow them to be Loaned / Shorted against max 1 times. other wise if marker reflects share is already oan it wont be eligible. This makes a good motivation to move to an NFT like or Blockchain type basis for shares. Short reporting should be daily. Consideration around a limit on ratio / Limit of shares traded on dark pools vs shorts entered on LIT exchanges acquired to prevent manipulation. - Shares acquired and exclusively traded in Darkpools should only be allowed to be shorted in those environments to prevent Dumping of short positions onto Lit exchanges leaving only retail traders exposed to their effect without of the balance of the upside reflecting on lit exchange for the acquisition and trading of those shares. Margin and interest should increase proportional / exponentially to the total short interest , to prevent over shorting from nefarious intent (bankrupting companies to collect on shorts) - for every 1% in short interest the cost/interest rate of shorting should increase Thank you