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Re: kingpindg post# 328214

Friday, 12/14/2018 2:54:51 AM

Friday, December 14, 2018 2:54:51 AM

Post# of 360778
Thanks King. Useful information from FINRA. Now if they could only address the issue of non-reporting or under reporting...

Yes, there is obviously a requirement to report, but is everyone in complete compliance at all times? To use an example of parallel requirements that exist elsewhere in industry that others might relate to - OSHA has requirements for employers to maintain a log and summary of employee injuries. There are penalties in place for those who fail to comply. Yet at the same time it is important to bear in mind so many companies track employee injuries as one of the numerous key performance indicators (KPIs) that their respective managers are measured by in order to qualify for their certain performance bonuses. Lower injuries reported would seem to imply fewer losses and some (hope) it reflects better performance in terms of injury prevention. Nevertheless, in certain instances management teams are influenced by their own greed and personal interests to suppress such reporting so they can receive their bonuses. Every once in a while you hear of the employee who is injured at work and because of such pressures exerted on them they may falsely claim that the injury happened off the job instead of on the job. Makes the boss happy because it does not ruin their safety record. So the point in this is to ask that just because an injury is not appear on an employer's OSHA log and summary does it mean that it did not occur? No - not at all, it simply means it was not properly reported.

But how can that be? It's a legal requirement?! Can non-reporting of shorts per FINRA rules occur as well? Certainly, if the entity with the obligation to report deliberately or unintentionally fails to do so. Have there been fines and penalties levied on firms for violations relating to short reporting? Yes, take a look at some of the posts earlier about fines firms have had to pay relating to naked shorting and failure to deliver. Do the fines and penalties related to those circumstances also create some of those very same types of influences mentioned with respect to injury reporting? Do firms wish to avoid paying hefty fines and penalties in much the same way managers wish to make sure they receive their bonuses?

The question you have to ask your self is whether you believe that everyone is completely honest at all times and do what they are obligated to do? Does everyone always do the right thing? Hmmm... most of us wish to be able to have complete faith and trust in our fellow man, but are they always completely honest, diligent, forthright and trustworthy? Former president Ronald Reagan said once, "trust but verify." And we do our due diligence by going to the proper authority and doing our verification with the information we have readily available. But is that enough? By trusting FINRA but verifying by double checking elsewhere, we see what appears as conflicting information between FINRA (http://otce.finra.org/ESI) and another resource (https://www.otcshortreport.com/company/ERHE) and now we have to try to determine who is right and who is wrong. For some it simply calls out the validity of one source or another (or perhaps both) as being questionable.