Proposed New Rule 2231 Regarding Transaction-Specific Disclosures for Customers in Debt Securities Transactions
Executive Summary
On May 18, 1998, the Securities and Exchange Commission (SEC) approved amendments to National Association of Securities Dealers, Inc. (NASD®) Interpretive Material 2110-1 (IM-2110-1) and Rule 2720, revising certain provisions of the Free-Riding and Withholding Interpretation (Interpretation). These amendments address direct and indirect owners of broker/dealers, investment
Re: FINRA Proposed Rule 3290Proposed Rule 3290 does not address the transition from Rule 3270 to the proposed rule. Specifically, to what extent and for how long would a previous notification and approval of an outside business activity under Rule 3270 satisfy the requirements of the proposed rule? Previous notifications and approvals under Rule 3270 should continue to be
Comments: I am strongly against limited access to leveraged and inverse ETF's. They are not in any way conceptually confusing and they are always accompanied by significant disclaimers describing their short term nature and the extra volatility expected. Limiting access to these products would decrease my ability to effectively manage the risk in my portfolio, especially on the short side.
Please require all institutions and bonafide market makers to report their short positions who are subject to 13(f). Real time reporting of short positions would be beneficial as well. SSR rule needs to also account for naked shares. There have been multiple cases of $gme and $amc being shorted on red candles instead of being shorted on green candles when SSR is active.
Dear Committee, While efforts to improve transparency are appreciated, I believe there is no mention of dark pools. There needs to be more transparency on shorting going on behind the curtains. Moreover, shorting needs to be regulated. There is certainly no need to short a business if there is no evidence of foul play by the businesses. Running businesses into the ground doesn't allow fair
I want in depth reports on short positions for any and every stock on the market. I also want reports on how many of those short positions are on loan as well as the strike numbers for each individual option. Secondly, short sellers (mainly institutions) should absolutely not be able to hold MASSIVE uncovered short options. They should be required to have covered puts before placing any puts.
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
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Each year, FINRA publishes its Annual Regulatory and Examination Priorities Letter to highlight issues of importance to FINRA's regulatory programs.
Cover Letter From FINRA President and CEO, Robert Cook
January 8, 2018
As is our practice, we are marking the start of the new year by publishing our
FINRA seeks comment on proposed amendments to FINRA Rules 5110 (Corporate Financing Rule—Underwriting Terms and Arrangements), 5121 (Public Offerings of Securities With Conflicts of Interest) and 5123 (Private Placements of Securities) to make substantive, organizational and terminology changes to the rules.
