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to the edge of disaster, in large part due to systemic risk developed under the regulatory authority of FINRA's outdated short interest reporting policy.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to the edge of disaster, in large part due to systemic risk developed under the regulatory authority of FINRA's outdated short interest reporting policy.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

Consolidation of short interest data publication, centralized on the FINRA website should be made public. Require firms to segregate short interest held in proprietary accounts vs that held in customer accounts. Report to FINRA account-level short interest (not for publication). Report synthetic short positions in both options and security based swaps. Report loan obligations from arranged financing to better reflect actual short sentiment. Report total shares outstanding and the public float. Daily reporting timeframe. A daily report of FTD allocations at the security level.

To whom it may concern, I am an individual investor with no special expertise in financial markets or their regulation. However, I am a scientist who performs a lot of data analysis, statistics and machine learning for my profession, and therefore I believe I have more than enough expertise to analyze financial data that is available. In order for informed decisions to be made, whether in finance or science, one has to have all the data available.

Improved reporting for short positions is long overdue. As proven by the research done on "meme stocks" like GME and AMC there are a wide variety of ways for institutions to hide their short positions from others. Some of these include shorting of ETFs, using married puts and other options plays and simply lying with willingness to accept a small fine. The market overall needs more transparency so individual investors can make more educated decisions. If you proceed with strengthening the reporting requirements for short positions the penalties should also be more severe.

I would like to comment on the Short Interest Position Reporting Enhancement. I do agree synthetic short positions should be reported. There should definitely be a TSO and Public float report, and it's almost sad that there isn't one already. The reports should come out daily. There's no reason why firms can have super computers doing High Fequency Trading but not have the capability of electronically sending position reports in REAL TIME.

"Hello and good evening. I'd like to start by thanking you for being open to comments from retail traders. I am a retail trader from germany. I am not the most financially literate person in the room, as my experience investing has been limited to this year, but in that time I have made great strides in learning how our financial system functions. I parsed Regulatory Notice 21-19 myself so that I, as a young American and novice investor who looks forward to a lifetime of activity and learning in the free market, could provide my original thoughts. "A.

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.

As a retail investor I would like to see many changes made to the way you gather short position information. I like collecting the information daily and also reporting synthetic shares. It seems to me that the market markers and hedge funds have way too much freedom to do as they see fit with very little oversight and little to no punishment handed out when they are caught in the wrong. Real penalties need to be handed out so they will stop and we can have an actual fair market. As of right now i for one will be looking to this as my answer. Either I stay or I go based on your decision.

The state of the United States financial markets is a disgrace in no small part due to egregious abuse of short selling. Skirting of the current rules and regulations is commonplace and the penalties of such behavior, even when caught, are laughable given the profitability of such behavior. Both the prevention of this criminal activity and bolstering of punishment for said activity must be addressed in order to have effective and orderly markets.