Joe Comment On Regulatory Notice 21-19
All short positions, short interest, and related information should be immediately filed for public disseminating and with penalties for retroactive amendments filed after the end of the period
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All short positions, short interest, and related information should be immediately filed for public disseminating and with penalties for retroactive amendments filed after the end of the period
All, 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to the edge of disaster, in large part due to systemic risk developed under the regulatory authority of FINRA's outdated short interest reporting policy.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.
Anything that could be done to increase simplicity in the rule book would be a huge benefit to the market. I AM NOT SAYING TO DECREASE REGULATION: I am advocating for an increase of regulation with incredibly simple language so that it is accessible to anyone. OVERSIGHT AND TRANSPARENCY SHOULD BE THE UTMOST AND ULTIMATE PARADIGM. Increase transparency on all positions, real and synthetic, long, short, derivatives- everything. On top of that it should be publicly accessible. It should be concise and regular, at the latest updated on a weekly basis and apply to ALL MARKET PARTICIPANTS.
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to the edge of disaster, in large part due to systemic risk developed under the regulatory authority of FINRA's outdated short interest reporting policy.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.
Every share should be tracked with unique identifier. Every share should be located and lent only once. Every order should be delivered T+2 or fails mean 10x cost penalty. Every short position should be updated with FINRA daily
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.
Report short interest and all relevant information DAILY. End loopholes allowing short interest to be artificially hidden with “married calls/puts.” Do something about the relentless and abusive practice of naked shorting. Everyone sees it but the general public cannot do anything about it. Are shares of everything we own are getting significantly and artificially devalued through this rampant but illegal practice.
FINRA 21-19 is a long overdue change. The market is a nonsensical mess as a result of the outdated "regulations" and lack of proper enforcement. You've encouraged a system that promotes Loopholes. Regulatory Notice 21-19 NEEDS to be sweeping across all aspects of reporting and closing and holding and marrying or whatever other terms or strategy's relate to Shorts and Reporting and Closing. Anything less is defrauding the FREE market. This is not a BURDEN for the Market Maker, this a responsibility.
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.
As all short interest affects market pricing, all transactions between market participants that may be used to mask or hide official short interest numbers should be reported fully and transparently. It is against the idea of a free market to withhold short interest data from all market participants, including retail investors, and to only provide information to professionals.