R. Wolfe Comment On Regulatory Notice 21-19
1. T+0 settlement 2. Market Makers cannot be hedge funds. 3. Stock in hand rule ie short seller must have found and received stock before it can be shorted. 4. Public list of every entity which short sells a stock. 5. Maintenance requirement to short a stock to be cash only with zero marginable securities used as collateral. 6. Fine for Naked Short Selling enhanced to 1000% of stock's value plus lifetime ban from all trading activities, to include consulting services offered. Also, all monies made secondary to short selling must be forfeited. For example: if a short-seller invests the proceeds and those proceeds result in a net change, then those monies must also be forfeited. Many institutions have used the proceeds from naked short selling ( accumulating FTDs) to invest in speculative crypto currencies which have yielded exponential gains. 7.if a security is placed on SHO Threshold Security list, then it cannot be shorted, including short ladder attacks, until all FTDs are resolved. 8. Lifetime Ban for any entity which has ever defaulted on an FTD, or been associated with such entity (person, place, or thing). 9. Make any entity, which creates an FTD through short sellling, an additional responsible party with the broker for a stock which has been loaned for the purpose of short selling. Ie make the short seller responsible for all damages incurred as a result of a stock being sold short. 10. Shares from a private, public, or group holding must be specifically labeled as “approved to loan for the purpose of short selling”. The holder of a share loaned for short selling must give permission specific to said stock within 24 hours before the stock is loaned to be sold short. This permission must not be bundled with standard language in a hypothecation agreement, but instead shall be in addition to such agreements. I may submit further comments.