Jimmy James Comment On Regulatory Notice 22-14
I am a retail investor. I believe OTC options trades are a great systemic risk as they are not properly regulated. As FINRA is an SRO I believe it should be required that all OTC options chains be publicly disseminated in order for regulatory integrity and public trust to be maintained. In order to maintain competitiveness and not price smaller firms out of the market, FINRA should create a system of standards by which all forms can submit OTC options trades daily and seamlessly, without incurring heavy costs. The data collected should then be publicly published such that the public can keep FINRA honest in its duties. It should also be such that costs of upgrading equipment to maintain regulatory integrity be cheaper than the fines for avoiding the mandatory reporting. And the fines that are seen as a cost of doing business for failure to report should be great proportional to the failure, such that it dissuades corruption at all financial levels. Only reporting options of bulk orders of 200 contracts seems like too broad of a sieve. I believe it could be reported as low as bulk orders of 50, 10, or 5 contracts. As I am not an expert, I cannot determine the exact consequences of my proposals. However I believe what I said is necessary to maintain integrity and public trust in the market.