July 17, 2006
-Eliminate the criminally-complicit grandfather clause
-Enforce (and therefore limit) "for the sake of liquidity" provisions after clearly defining them, of the naked shorting exemptions of the Options Market Makers and Specialists, or preferably, since self-regulation is a license to steal and enforcement would be onerous, eliminate these exemptions. There can be no fair market so long as these MM's and Specialists can create extra "shares" to mitigate to trivialization or roll forward to infinity their own risk and that of their hedge fund and other institutional customers
-Require a borrow first, not later which can equal never-forever on companies targeted by short sellers and complicity MM's and Specialists
-Require a borrow be documented no single share should be borrowed and sold and re-borrowed and re-sold more than once/repeatedly
-Report short sales, total short interest daily with same transparency and public reporting of total daily volume.
-Settle all trades within 3 days, buy in Failures To Deliver immediately on day 4. There is no legitimate rationalization for any extended period of manipulative counterfeiting of shares created from thin air.
-Audit the stock loan program of the DTC/DTCC and all its subsidiaries and establish oversight to assure settlement accuracy -- and prevent the hiding of over-voting of proxy shares