Subject: SR-FINRA-2023-010: Webform Comments from Brian Herrmann
From: Brian Herrmann
Affiliation:

Oct. 5, 2023

This is regarding SR-FINRA-2023- 010, where FINRA is
proposing to add new paragraph (“Protected Options”) to FINRA Rule
4210 (Margin Requirements).

Placing more obfuscation on any trades/position is **not helpful** to
fair and open markets. You cannot guarantee that you can exercise a
call and come up with the shares needed to fulfill your shorts. FINRA
is trying to suggest that ‘any’ long position can offset a short
without confirming if they are able to consistently cancel each other
out.

This is so sneaky and devious! Reading through their proposed
language, all I can see is that it opens up more paths for price
manipulation - crippling the ability of the market to accurately value
securities. 

Copying the corrupt actions of the CBOE does not make this fair,
reasonable, or necessary. All it does is obfuscate reportable data and
make SEC enforcement more difficult when trying to protect free and
fair markets.