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Russell Cohen Comment On Regulatory Notice 21-19

Russell Cohen

With all due respect "reporting" is a small part of the shorting problem. While I support more immediate reporting requirements, the issue is naked shorting, mislabeling of shorts (as longs), and other shorting malfeasance being used by market makers (i.e. Citadel and Virtu) to manipulate market prices and destroy market integrity. Fines are also the biggest joke. Citadel has been fined for illegal shorting practices and FTDs in the past and the criminal activity continues to this day. It would be great if FINRA could require lower margin requirements for short sellers, with daily reporting backed by commensurate fines matching the shorted activity flow dollar amount, as well as prohibiting shorting by market makers who control order flow, are engaged in PFOF, and trade in dark pools. Can't have the fox also guarding the hen house. This rigged market has of course been exposed most recently through "meme stock" communities shedding light on rigged trading activities in AMC and GME. Until retail investors can rely on fair and regulated markets we will continue to ring the alarm on these nefarious trading practices which seemed to have continued unabashedly under the tacit acceptance (or complicity) of financial regulators. But until then, I support any efforts FINRA has to bring greater fairness and transparency to the markets through a more rigorous and timely reporting structure. But we need strong penalties or these low life hedge funds will continue to make a mockery of our system. Thank you.