When reporting short interest can be skewed through a loophole, this needs to be addressed. When short sale restrictions are enacted as a safety for a volatile stock, but overridden through a mysterious, unregulated exchange: this needs to be addressed. When asset managing/ trading firms have access to order flow prior to retail investors, and can systematically alter a stocks natural and organic movement: this needs to be addressed.

The Reporting of Loan Obligations as Short Interest. Theory suggests that some participants are borrowing shares from ETF's to cover their existing short interest. This only results in the same exposure continuing to exist elsewhere in the market, in effect, the short position has not been closed, but rather, is moved off the books which affects the integrity on both ends of the affiliate program.

I think retail is extremely desirous of seeing more frequent reporting and as much of that made publicly available as possible. At least of a weekly or bi-weekly basis. I believe the currently attempted short squeeze is bring to light that lack of transparency is being used to commit fraud and establish predatory roles against companies. The watering of stock has been an issue for nearly a century. It would be financially irresponsible to not increase regulation in these regards.

I strongly support stricter reporting requirements on short positions held by market makers and prime brokerages. It is increasingly necessary that FTD information be presented to the public as a way of not only limiting abuse of the FTD system, but also to reveal obfuscated information that is not readily available to the market and is often times concealed or miscategorized in reporting.

As a self-regulatory conglomerate it is beyond the reasoning of a "retail" investor as to why such ordinances do not already exist. The SEC itself has proclaimed naked-short selling to be a well established predatory and dangerous practice that undermines the free-market operations of millions of non-institutional investors who cannot play by the same rules. In addition to the regulatory capture here, it should be seen as important for FINRA to also enforce penalties in accordance to the scale of their misdoings.

I am encouraged that you are considering changes on the subjects of Short Interest Position Reporting Enhancements and Other Changes Related to Short Sale Reporting. These changes are will open the way to fair market operations. In the current environment the technology and information for market operations is far superior compared to what is available to regulators and ultimately the public. That tech is being abused in an aggressive manner which is in turn creating blind risks for the investing public.

I am in favor of these proposed rule changes. Specifically the disclosing of synthetic positions. It is vital that this information be made available to combat predatory trading practices. Practices that artificially destroy businesses and lives. If we cannot eliminate the loophole that allows for synthetic naked shorting, getting as much information made public is the next best thing. Perhaps it can save many businesses from closing and jobs from disappearing.

Hello FINRA, I saw you are looking for comments on 21-19, regarding short positions. As I see it, the current US market is full of fraud, with the regulatory agencies being complicit. They are complicit through their complacency, with years of unchecked fraud and market manipulation through naked short selling by large hedge funds like Citadel and Susquehana being allowed to happen with impunity. The SEC and FINRA have known about this illegal counterfeiting practice for many years, with nothing being done to rectify the illegality of the market conditions. Naked shorting is illegal.

Short interest reporting by all of these entities should have complete transparency. Failures to report on possible FTD’s, never delivering those shares or marking short positions as long should result in repercussions equal to the actions. Small fines or as they can be referred “the cost of doing business” for some of these funds or entities are unacceptable. Reporting should be even more frequent as streamline the process of collecting accurate data.

All short positions SHOULD BE disclosed. Any stock lending should be subject to daily reports. Keeping the data hidden hurts retail investors, as the price is being affected by things they are unable to see.