FINRA 21-19 addresses many of the shortcomings of our opaque market. While I support the reporting enhancements, I would like to see further action taken by FINRA to bring transparency to short selling. Short selling, while providing liquidity to the market, also brings the challenge of unlimited risk. Unlimited risk (e.g. a short squeeze) drives market participants to engage in unethical and illegal behavior.

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to the edge of disaster, in large part due to systemic risk developed under the regulatory authority of FINRA's outdated short interest reporting policy.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 a unique identifier. Every share with a unique identifier should only be allowed to lent out once. Every order should be delivered T+2 or fails mean 10x cost penalty. Every short position should be updated with FINRA daily. All retail but and sell orders should be done in a "lit" market - not retail order should be allowed to be packaged up with other retail orders and sent as "one" to a darkpool. Market Makers should not be allowed to be owned by hedge funds like Citadal or other clear conflict of interest institutions.

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to the edge of disaster, in large part due to systemic risk developed under the regulatory authority of FINRA's outdated short interest reporting policy.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to the edge of disaster, in large part due to systemic risk developed under the regulatory authority of FINRA's outdated short interest reporting policy.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

Please excuse the form comment but the OP stated my concerns better than I could articulate. 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.

We really need robust oversight if we are going to allow these reckless gamblers making the very markets. Selling something that doesn't exist. Creating fraudulent property. selling the same property to multiple investors. Shorting stocks that don't exist. Selling stocks that don't exist. This damages the faith of the people that markets are fair and safe. This hurts people. We have this opportunity to show transparency and good faith before irreparable damage, revolt and foreign investors losing faith in our markets.

I'm writing to request more transparency, fairness and accountability in our financial markets, as all of us rely on our regulatory entities for that assurance. There are some things that are of particular interest to me: 1. Transparency of Buy/Sell orders in the market as a whole, including but not limited to OTC/ATS off market trading. 2. Information market makers have when it comes to filing for a short position should be made known to everyone, including retail traders. 3. Short positions should be covered by everyone at close of day, no more T+ non sense. 4.

As a programmer, a major source of frustration for me regarding many facets of our market relates to the fundamental lack of speed and automation endemic to our financial reporting pipelines. In a system which promotes and rewards algorithmic and high-frequency-trading, any position which would be reported and analyzed as a document and by a human would (and very likely is!) obsolete, potentially wildly so, by the time it was viewed.