May 5, 2009
Why are you trying to reinvent the wheel?
Restore the uptick rule to the exact equivalent of what it was.
Why? Because it is time-tested. Decades of experience have proven it.
1) Allow short-selling, all the time.
2) Enforce the uptick rule, all the time.
3) Ban naked shorting, all the time.
BOTH the "price-test approach" and the "circuit-breaker approach" complicate and obscure the original problem: namely, the elimination of
the uptick rule.
To compare the uptick rule's effect on trading to the effect of the temporary ban on short-selling (as does the representative the Credit Suisse) is nonsense, a fallacy, and an insult to intelligence.
If you follow "tests" made around '05 (or so) you make the same error made by the mathematical models that brought on the subprime mess,
namely, an INADEQUATE BASELINE. This is an insult to intelligence, common sense, and Street sense.
Finally, under the restored uptick rule, short-selling and programatic short-selling should cost, effectively, what they cost under the old rule.
Otherwise, nothing will be restored.
The costs of the uptick rule are part and parcel of the effect of the rule.
Short-selling is a brake on buying, but so is plain selling. Short-sellers
talk as if there were no other way. But there is, and it's called, "selling."
Plain selling is simpler than short-selling and, it shouid be effectively cheaper.
Short-selling is, effectively, a quasi-derivative of selling.