December 22, 2005
Each public companys transfer agent should be in the clearing process loop. If it adds 3 seconds to a trade, so be it. The transfer agent should keep current records of who owns shares in what type of account, who is lending shares and who is borrowing shares. The transfer agent would block any transact unsupportable by its accounting. Identities can be kept secret but totals would be currently available to the market. Get rid of the DTCC all together.
In addition, why dont we decentralize Wall Street completely with 10 regional exchanges? Right now, Wall Street and their pals use the state Blue Sky Laws to herd all the corporate sheep to the Wall Street slaughter house. Let new corporations raise money easily by belonging to a regional exchange of their choice, subject to acceptance by that regional exchange and to registration of its shares by that regional exchange. The new corporations stock would trade exclusively through members of that regional exchange. If naked short selling or pump and dumps or corporate fraud starts at a regional exchange, investors and new corporations will flee to another regional exchange until the mess is cleaned up. Money will flee fraud with notice and a choice. New corporations will choose regional exchanges wisely. Foreign fraudsters will be completely locked out. Honest business can go about its business with easy access to capital through registered shares. No more hand to mouth, family and friend rounds because the bank wont lend. A regional exchanges reputation for honesty will be its most valuable asset.
Thank you again for this opportunity to comment.