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Jesse Jewkes Comment On Regulatory Notice 21-19

FINRA reporting should fully cover all positions held in publicly traded companies. The reporting period should follow the standard settlement period. All reporting should be made available to the public within 2 hours of market close on a daily basis. All positions, including short positions should be required to be included without exception. Failure to accurately disclose a short position in the allocated reporting period should result in an immediate penalty.

Joseph Bumstead Comment On Regulatory Notice 21-19

We need much stronger regulation, this could be a step in the right direction. Here are some suggestions for that regulation: - Make the time to deliver a share to its buyer legally 3 days. That's right, 3, give them a bit of leeway. - Remove all the extra extensions. Instead, we allow them to roll for another 3 days. They _must_ do this indefinitely, until they locate and deliver the stock.

James M Fox Comment On Regulatory Notice 21-19

To whom it may concern: 1. Consolidation of short interest data publication, centralized on the FINRA website should be made public. 2. Require firms to segregate short interest held in proprietary accounts vs that held in customer accounts. 3. Report to FINRA account-level short interest (not for publication). 4. Report synthetic short positions in both options and security based swaps. 5. Report loan obligations from arranged financing to better reflect actual short sentiment. 6. Report total shares outstanding and the public float. 7. Daily reporting timeframe. 8.

Brian Ochs Comment On Regulatory Notice 21-19

To Whom It May Concern, I believe FINRA themselves said it best in their proposal, "FINRA believes this information would assist FINRA in understanding the scope of market participants’ short sale activity, specifically regarding the use of less-traditional means of establishing short interest." My only question is why in the world has FINRA not required ALL short interest? Isn't the whole point of a Short Interest report to show how much Short Interest there is? Why in the world would you ever exclude all the Short Interest information unless it was for nefarious purposes?