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to the edge of disaster, in large part due to systemic risk developed under the regulatory authority of FINRA's outdated short interest reporting policy.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

Domestic and international retail investors are in dire need for a transparent and fair free market. Public scrutiny of market makers, investment firms and brokerages is at a tipping point where the average investor does not believe in a fair market. Individual investors are uncovering evidence of insider trading, price manipulation of securities sold in the NYSE and more importantly "Dark Pools". To restore trust in the American Stock Exchange; Market makers, investment firms and brokerages must be held to the highest standards.

FINRA 21-19 is a long overdue change. It is critical for the survivability of the US Markets that transparency and trust remain with to sustain it. Recent events have called that critical trust relationship into question, and as an American who serves this country, I urge FINRA do its utmost to ensure that the integrity of the United States markets remain intact. Unfortunately, businesses have proven that self-reporting and self-regulation do not work, and thus government regulation needs to step in to ensure markets are fair and equal for all participants to ensure continual survival.

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to the edge of disaster, in large part due to systemic risk developed under the regulatory authority of FINRA's outdated short interest reporting policy.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to the edge of disaster, in large part due to systemic risk developed under the regulatory authority of FINRA's outdated short interest reporting policy.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

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.