I am in support of FINRA being in control of the short interest compilation and most fine grained dissemination. I am in support of the most extreme reporting conditions. Reporting should be daily, there is too much time for them to change their books. There is also zero reason they can't report their holdings daily, they have computers, it's not like they actually do anything without them... They either are not allowed to have any positions, if they are part of market infrastructure, or they must report every single thing, everything.

Regulatory Notice 21-19 addresses the general breadth of exploitable and ineffective reporting, they also leave significant gaps compromising the entirety of 21-19’s purpose. It is critical for the restoration of both the stability of the US markets and confidence of investors with in it that all regulation changes regarding short interest reporting be effective in every known circumstance where short positions, synthetic or not, can go unaccounted for with any length of time greater than any other short position deadline.

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.

I am writing to request that FINRA reform their short-sale and FTD reporting to the highest enforcement standards possible. Specifically, I am concerned that FINRA's current blindness with regard to alternate formations of short interest through "married puts" and arranged financing leads to unquantifiable systemic risk which can then be rolled over indefinitely with low borrow rates until one (or many) grossly overexposed broker's default becomes everyone's problem.

You need to take care of this mess, or I will never trust the markets again. Naked shorts are ridiculous. Reporting should be done on a daily basis. It’s 2021 and digital storage is cheap. I can’t tell you how angry I am at this whole game stop saga. Get your [REDACTED] together. https://www.reddit.com/r/Superstonk/comments/pynfk9/finra_complicit_this_is_big/?utm_source=share&utm_medium=ios_app&utm_name=iossmf

To Whom it May Concern, Thank you for requesting comments on this matter. I believe short interest and short sale reporting plays a major part of our current financial structure. Such a major role, that it is surprising how lax the overall rules are governing this aspect. I'm as smooth brain as they come, but I truly believe in clear and open transparency to the public is a way to help regulate the market. How can we say this is a free and fair market when we allow short interest to not be reported properly or timely?

I am a retail investor in my later 30's. I have only been contributing to my 401(k) for the last 4 years, and opened my Roth IRA in early 2020. I have not been investing very long, and plan to be working another 30 years before I'll have enough to retire on. I tell you this only because I want you to understand how totally and completely the last 18 months have shaken my confidence in our stock markets. I used to think that while I did not have the influence or capital to shape any part of the market, I did believe that FINRA was there to protect the interest of unimportant people like me.

Regarding FINRA 21-19, this is a great start for more oversight into U.S. markets. While more attention in my opinion should be paid to the effects of short interest, I support FINRA 21-19.

With how poorly the entire market is run, anything that enhances the ability for retail investors to have more transparency is a must. With how easily everything can be manipulated, data being skewed and hidden, naked shorts, FTD's, etc - the entire system needs an overhaul. But at the minimum, 21-19 needs to be passed to allow better transparency involving the reporting of short interest and short sales.

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.