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Sam Park Comment On Regulatory Notice 21-19

Sam Park

A transparent and accountable market should be the lowest bar. This seems like a minimal step forward, particularly on a higher frequency and timely reporting, expanded information on account level positions, threshold securities, and ownership of synthetic shares. Please do more than consider these enhancements. I had no idea that there was financing available to cover shorts - this seems ethically ambiguous at best. Other conflicts of ethics that should be addressed are a separation of market maker status from any institution that is affiliated with hedge funds, no use of options as collateral, harsher repercussions for irresponsible practices such as naked shorting, or synthetic options plays.