May 8, 2014
i think this whole program needs to be reviewed by the SEC:
1) what constitutes a "qualified marketmaker".
2) whether rebates should be paid and why any fees should be increased or decreased.
3) whether NASDAQ should report daily transactions to FINRA in their entirety to be made public. significant # of shares are unreported.
4) NASDAQ reg SHO list and short sales list are incorrect. perhaps someone should review why this is so.
i am totally weary of hearing how any changes would benefit the investor or the market without explaining why the practices would benefit the investor. it is investors who provide liquidity in terms of $ but it is not particularly helpful to buy shares that are late in being delivered. it is not helpful for shortsellers to drive prices downward with volume, overwhelming the demand for those shares. this is a simple idea of supply and demand. any NASDAQ requests that aid shortsellers do not benefit investors because their portfolios will reflect lower prices. while these practices may decrease the price per transaction for investors, the practices also will decrease the value of their portfolios.
in addition, the SEC should review NASDAQ order types, particularly display only order type. the market should be able to see any order that is put up for execution. while NASDAQ appears to speak for the broker/dealers, some of these practices are at odds with the investors. shortsellers are not investors in the market, they are a capital outflow from the market. capital outflow is not capital formation and does not benefit the economy.
NASDAQ should not submit such things "for immediate action" unless there is a justification for doing so. i see no justification for an urgency in this matter.