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Sung Lim Comment On Regulatory Notice 21-19

Sung Lim

Rule 1. All short sale shall be reported to finra by end of each settlement day. Rule 2. Finra shall make public report the day to day short sale by end of settlement day of the trading week. Rule 3. All unused loaned shares shall be reported to finra by end of settlement day. Rule 4. Finra shall make public the outstanding unused loaned share by end of settlement day of a trading week. Rule 5. All threshold securities sho regulation shall be reported daily with full accounting of fail to deliver end by end of settlement day. Rule 6. Finra shall enforce FTD purchase upon noncompliance with 2 settlement days. rule 7. Upon evidence that any existing FTD has been rectified, no securities broker/vendors shall provide additional securities by means of loan, borrow, lending. Rule 8. All retail order flow that goes through dark pool and/or unregulated channels shall be marked DF-sell and DF-buy Rule 9. Due to conflict of interest, any affiliated companies/subsidiaries with ownership greater 1% shall not have securities order flow through the affiliated entity. Order flow must be placed with a and third party to avoid conflict of interest.