FINRA 21-19 is a much-needed update. The integrity of the US market has clearly been stressed to the point of disaster, owing in large part to systemic risk established under the regulatory authority of FINRA's antiquated short interest reporting regulation. While many of the measures described in Regulatory Notice 21-19 address a broad range of exploitable and ineffective reporting, they also leave major particular holes that could jeopardize 21-19's overall goal.Any and all regulation changes regarding short interest reporting must be effective in every known circumstance where effective short positions, synthetic or not, can go unaccounted for for any length of time greater than any other short position reporting deadline for the restoration of both the stability of the US markets and the confidence of the investors within them. Furthermore, the cost of operations for eligible market participants to meet these requirements cannot be justified when compared to the cost of a harmed market with systemic risk, or the loss of investor confidence and participation in the US economy.
Brittany Iogan Comment On Regulatory Notice 21-19
FINRA 21-19 is a much-needed update. The integrity of the US market has clearly been stressed to the point of disaster, owing in large part to systemic risk established under the regulatory authority of FINRA's antiquated short interest reporting regulation. While many of the measures described in Regulatory Notice 21-19 address a broad range of exploitable and ineffective reporting, they also leave major particular holes that could jeopardize 21-19's overall goal.Any and all regulation changes regarding short interest reporting must be effective in every known circumstance where effective short positions, synthetic or not, can go unaccounted for for any length of time greater than any other short position reporting deadline for the restoration of both the stability of the US markets and the confidence of the investors within them. Furthermore, the cost of operations for eligible market participants to meet these requirements cannot be justified when compared to the cost of a harmed market with systemic risk, or the loss of investor confidence and participation in the US economy.