Subject: Release No. 34-100046; File No. SR-FINRA-2024-007
From: Suzanne Shatto
Affiliation:

May 22, 2024

i think this is a great idea. 
yes, there should be a central data repository for lending and shortselling information. 
yes, FINRA should be the agency that implements it. 


the shortselling loan should be tied to the shortselling transaction, accessible to the clearinghouse so that they can use the shortselling loan to cover during clearing. data should be created when the transaction begins. regulators should be able to view this data. 


no loan available to be sold short? 
then the shortseller cannot create the short. 


if brokers have shares to lend, they can create the data in the repository. (creating data without having the shares available to short should be penalized by a good-sized fine. third time, maybe someone should go to jail for attempted manipulation.) if shortsellers want to borrow, they can get some of those shares allocated. and if no shares, they cannot short that transaction. 


no pre-allocation of shares allowed. if you borrow lent shares, you need to have a time limit and either use them for a transaction OR return them to the repository. libraries operate a checkout system similar to this. 


no wondering "where's waldo". 


computerized trading needs the same guardrails as everyone else. 


make it strong because lots of entities WILL NOT LIKE IT. and since the have succeeded at being a criminal, they won't have any problem trying to crash the system. 


banks are going to have to make $ the old-fashioned way. and they won't like that either. perhaps they will have to pay their broker employees less. 


yes, the financial industry will NOT like this. but it is the right thing to do. capital markets are for the benefit of the investors, not the parasitic entities that are trying to take their $. 


good luck with this. 
i see 2 comments, both positive, other than my positive comment. 


hoping for fast implementation. 


shortsellers are not investors. they take $ out of the capital markets. they live off the $ that investors put into the market. they are parasitic. 
they don't "discover prices". they CAUSE lower prices. they communicate with each other about bear raids to surprise investors and try to get them to sell because the investors are afraid of them. 


make the stock market trading be between a natural buyer and a natural seller, not all these people living off of $ from the investors. why should people get to take investors' $ with the regulators' blessing? 


why do i think those shortsellers have not commented? they probably have scheduled meetings with the SEC to "express their concerns". i'm "expressing my concern" about the process of rulemaking. 


teaching banking staff how to evade the rules is probably not a good thing. you are taking college graduates and teaching them how to be thieves because of the loose regulatory environment. i don't think this is a good thing. this is not why I went to college. what do you think will happen to the morals and ethics of the college graduate? 
(if they do this, they get lots of $$$. if they don't, they don't get much $$$.) 


options, derivatives, they were all created to prolong a short raid. 



-- 



sincerely, 

Suzanne Hamlet Shatto 
shamlet76@gmail.com