From: Mhat McCane
Thank you for your request for comments. As an individual retired investor, I follow my holdings on a daily basis - I don't trade daily, but I do stay aware. Reg SHO has brought some visibility to a long standing problem in the marketplace - one which Chairman Cox eloquently covered in his opening remarks. Now that the problem has been defined, we are left with what to do. My suggestions:
1. Rescind the Grandfathering and force buy in of FTD positions. Anyone who is still sitting on a FTD position is totally unaware and should not be in the market. By the time public comment is reviewed, anyone with a FTD position will have had another 6 months to clean it up.
2. Do not allow future FTDs. Link delivery of shares to the buyer to clearing of funds to the seller. No shares, no money.
3. Allow short sales ONLY if real shares are borrowed before the sale.
4. Rescind the "locate" loophole. I believe the "locate" borders on violating Reg T and, in any event, does not deliver real shares to the buyer (see point 2).
5. Eliminate the exception for Market Makers - again, see point 2.
Finally, the key to any action is enforcement, enforcement, enforcement. Without it, the bad guys are going to pull a "Cramer" (write BS of your rules and throw them on the floor), on you and once again you will be labled as ineffective if not complaicent.
Thank you for your attention.