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James M Fox Comment On Regulatory Notice 21-19

To whom it may concern: 1. Consolidation of short interest data publication, centralized on the FINRA website should be made public. 2. Require firms to segregate short interest held in proprietary accounts vs that held in customer accounts. 3. Report to FINRA account-level short interest (not for publication). 4. Report synthetic short positions in both options and security based swaps. 5. Report loan obligations from arranged financing to better reflect actual short sentiment. 6. Report total shares outstanding and the public float. 7. Daily reporting timeframe. 8.

Brian Ochs Comment On Regulatory Notice 21-19

To Whom It May Concern, I believe FINRA themselves said it best in their proposal, "FINRA believes this information would assist FINRA in understanding the scope of market participants’ short sale activity, specifically regarding the use of less-traditional means of establishing short interest." My only question is why in the world has FINRA not required ALL short interest? Isn't the whole point of a Short Interest report to show how much Short Interest there is? Why in the world would you ever exclude all the Short Interest information unless it was for nefarious purposes?

Eric Woodside Comment On Regulatory Notice 21-19

While the proposed improved regulations / reporting are taking a step in the right direction there needs to be further reporting of data to the public made in as close to real time as possible. As the movement of retail traders being involved in managing their own investments continues to grow, the playing field should be as even as possible for all parties involved. If we are investing with a firm, we should be able to know the extent of their short position, if it is something that goes against our own investment strategies.