Personally I would set up an exchange that did not allow shorting of any kind which are death to these penny stocks. Prior to any trading all certs would have to be on deposit with an approved depository preferably one managed by the exchange and all the shares properly accounted for and signed off.
Your exchange would be totally illiquid. Illiquidity was what killed the Arizona exchange.
Register for free to join our community of investors and share your ideas. You will also get access to streaming quotes, interactive charts, trades, portfolio, live options flow and more tools.