Thank you for your time. Currently as it stands, there is too little information in true short positions. With a market makers ability to create synthetic shares for “liquidity”, at some point the true positions need to be accounted for. If a bank, a market maker, and or other parties can hide positions through layered securities like CDOs or swaps, there is no benefit to the market, only the entities on the short side benefit. It doesn’t show a true borrow fee for short interest, and is already a sign of two entities working in tandem, possibly in collusion.

FINRA 21-19 is a long overdue change. It is clear that the integrity of the United States market has been strained to the edge of disaster, in large part due to systemic risk developed under the regulatory authority of FINRA's outdated short interest reporting policy. While many of the policies mentioned in Regulatory Notice 21-19 address the general breadth of exploitable and ineffective reporting, they also leave significant specific gaps that could compromise the entirety of 21-19's purpose.

FINRA 21-19 is a long overdue change. It is clear that the integrity of the United States market has been strained to the edge of disaster, in large part due to systemic risk developed under the regulatory authority of FINRA's outdated short interest reporting policy. While many of the policies mentioned in Regulatory Notice 21-19 address the general breadth of exploitable and ineffective reporting, they also leave significant specific gaps that could compromise the entirety of 21-19's purpose.

FINRA 21-19 is a long overdue change. It is clear that the integrity of the US market has been strained to the edge of disaster, in large part due to systemic risk developed under the regulatory authority of FINRA's outdated short interest reporting policy. While many of the policies mentioned in Regulatory Notice 21-19 address the general breadth of exploitable and ineffective reporting, they also leave significant specific gaps that could compromise the entirety of 21-19's purpose.

Yes on 21-19 we all need more transparency in short positions and FTD data. In real time would be nice to truly make it a fair and free market.

FINRA 21-19 is a long overdue change. It is clear that the integrity of the United States market has been strained to the edge of disaster, in large part due to systemic risk developed under the regulatory authority of FINRA's outdated short interest reporting policy. While many of the policies mentioned in Regulatory Notice 21-19 address the general breadth of exploitable and ineffective reporting, they also leave significant specific gaps that could compromise the entirety of 21-19's purpose.

When Regulation NMS was adopted, the SEC and market observers did not recognize ex-clearing as a significant loophole. In the original crafting of Regulation SHO (implemented in 2005), the industry told the SEC that ex-cleared trades were "rare". As such ex-cleared trades were exempt from much of the short selling regulations. Dark pool trades (ATS and OTC) in 2021 now make up a significant part of daily trading volume. Approximately 40% is traded in these systems each day and it is not unusual to see as much as 70% of volume for some stocks being traded outside of the lit exchanges.

It is clear that the integrity of the United States market has been strained to the edge of collapse, in large part due to systemic risk developed under the regulatory authority of FINRA's outdated short interest reporting policy. While many of the policies mentioned in Regulatory Notice 21-19 address the general breadth of exploitable and ineffective reporting, they also leave significant specific gaps that could compromise the entirety of 21-19's purpose.

Hello I want to suggest a new rule with all financial operations of any kind by any broker is instantly reported, it's 2021 after all - and that all these operations were transparent and public via your websites - with multiple layers of depth so that "new" retail investors like myself could understand the basics easily - and that it would be multiple levels of depth for the more advanced. This could also be a source of information for you, as retailers especially would investigate if the market had unusual movements.