August 7, 2006
-Eliminate the grandfather clause
-Limit the naked shorting exemptions of the Options Market Makers and Specialists, or preferably eliminate these exemptions.
-Require a documented borrow first. No single share should be borrowed and sold more than once
-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.
-Audit the stock loan program of the DTC/DTCC and all its subsidiaries and establish oversight to assure settlement accuracy
-Prevent the hiding of over-voting of proxy shares
-Ensure DELIVERY with NO exceptions Only a UNIVERSAL DELIVERY REQUIREMENT will put a stop to delivery failures.