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Shane Heule Comment On Regulatory Notice 21-19

Shane Heule

SSR doesn't work when market makers such as Citadel Securities can still mark a short exempt. Short exempt is supposed to be an exception but every time $amc is on SSR the counts of short exempts is extremely high. Citadel's hedge fund profits from their market maker's ability to short during SSR as do the options contracts held by Citadel Securities. This is an unfair competitive advantage and similar to insider trading. Also there is no real punishment for violation of the uptick rule during SSR. And market makers and hedge funds can work together to short during SSR using ladder attacks. There needs to be real enforcement, punishments, and better defined exceptions criteria.