I am very strongly in support of strict regulations that require the reporting of synthetic short positions. Daily reports of such positions and all other short positions should be required. Fail to delivers in particular need much more regulation. In my opinion FINRA should place regulating FTDs as priority one. More frequent reporting, and shorter time to release FTDs to the public, as currently the SEC releases with a two week delay. The FTD reports should be released daily, and immediately, to the public.

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to the edge of disaster, in large part due to systemic risk developed under the regulatory authority of FINRA's outdated short interest reporting policy.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.

FINRA has a scaling problem. A problem that is observed in FINRA's inability to provide oversight and accurately regulate institutions as global markets expand and overlap. Transparency in our markets is essential. Transparency with respect to short interest reporting is severely lacking. Not only just the typical direct borrow and short transaction but also the use of derivatives and other short arranging products are not reported.

We are at a cross roads as an economy, thus as a country. Hedge funds and other similar large corporate entities have an unfair advantage in the market, and has acted to the detriment of the health of our economy as a whole. Loose rules related to the reporting of short interest and FTDs(fail to deliver) has created an environment that allows hedge funds and the like to take advantage of retail investors. Though illegal, naked short positions are rampant throughout the market. Under our current system, it is easy to falsify reports on short interest.

Please stop

FINRA 21-19 As a retail investor I have been concerned with the lack of transparency in short interest reporting. Confidence in the US market is wavering in part due to FINRAS out dated policies on short interest reporting. For a free market to exist we need reform and transparency for everyone.

Addressed to Yvonne Huber & Racquel Russel. Thank you both for requesting comment on Short Interest Position Reporting. I find it hopeful and positive that FINRA has acknowledged a gap in their ability to oversee Short Interest and Fail-To-Deliver Positions. In order to protect American investors (many of whom rely on equity positions ins 401Ks and IRAs to have a hope of retirement) FINRA must execute on the idea to publicize short positions, synthetic short positions, and cumulative FTD positions.

If you wish for the US and World to maintain confidence in our markets then change is absolutely vital. Without change, shortcomings will continue to be exposed and brick by brick your market will continue to crumble.

Our country and history has been brought about by change. Change that may have seemed difficult at the start, may have been viewed negatively, avoided, or even resisted, but eventually led to the greater good for all. This is no different. FINRA 21-19 is a change that needs to happen for the greater good of all. It’s a change that is long overdue and needs to be expedited into action. Where there are cracks for things to slip through, loopholes for entities and people to use and abuse, these things will happen.