Ian Freed Comment On Regulatory Notice 21-19
It is abhorrent that financial institutions are able to manipulate markets with zero consequences. They are able to insider trade and commit fraud. Why is there no punishment?
For the Public
FINRA Data provides non-commercial use of data, specifically the ability to save data views and create and manage a Bond Watchlist.
For Industry Professionals
Registered representatives can fulfill Continuing Education requirements, view their industry CRD record and perform other compliance tasks.
For Member Firms
Firm compliance professionals can access filings and requests, run reports and submit support tickets.
It is abhorrent that financial institutions are able to manipulate markets with zero consequences. They are able to insider trade and commit fraud. Why is there no punishment?
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to the edge of disaster, in large part due to systemic risk developed under the regulatory authority of FINRA's outdated short interest reporting policy.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 will help to restore some of my confidence in the US financial markets. I say some because 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to the edge of disaster, in large part due to systemic risk developed under the regulatory authority of FINRA's outdated short interest reporting policy. Healthy markets benefit everyone in the long term. Given the abuses I have seen, I have decided to remove all of my investments from the market unless substantial changes are enacted.
While short sales can be an important market mechanic to send signals to protect investors from corrupt or inept corporate leadership, hidden short sales and hidden synthetic short sales work against a free and fair marketplace. If institutional and "big money" investors detect reasons to believe that the future success of a company is unlikely, hiding their short positions at best circumvents the reasoning for short sales in a free and fair market, and at worst encourages bad actors to commit price manipulation at the expense of individual retail investors.
As a retail investor, I firmly believe that the market NEEDS more transparency and regulation. If the FINRA is going to collect information on short interest accounts, arraigned financing agreements, and Failure or To Delivers, they should collect as much information as possible and retail investors should be able to use that information to make informed decisions. A. Publication of Short Interest for Exchange-listed Equity Securities. All information gathered on this topic should be published publically and not condensed or consolidated. B. Content of Short Interest Data.
These regulations should have been in place 30 years ago. It is absurd to me that it took the public gaining awareness of short manipulation, and planned bankruptcy of many great companies by Hedge Funds to even get this on the table.
All short interest and FTDs need to be reported on a daily basis. Individual investors deserve to know what is going on with their stocks, especially when the entire system is computerized.
This market should be transparent. Reporting should be daily minimum... ftd's should be delivered... naked shorts(illegal) should be covered..fake shares can't be tolerated.... jail must be the penalty...... price manipulation should not even be possible let alone tolerated. All shares should be real shares.
Finra 21-19 is crucial to the integrity of the US stock market. Transparency and equal access to data is essential. The current imbalance in reporting and reporting requirements is severely crippling. The unlimited risk of naked short selling should not be allowed in our country. Failure to deliver data and short interest should be reported daily. Monetary and legal recourse are the only way to disincentive bad actors. The alternative is loss of faith in our financial market. The next generation of investors will find other mediums unless the course is corrected.
Retail investors do not typically have much to say during these critical junctures in financial history, but given the recent tumultuous events of the last year, and the potential systematic failures that can be eliminated by 21-19, I felt the need to lend my voice to the effort. Regardless of the viability of short selling as a legitimate investment strategy, the inefficacies introduced by short sale activities reporting have, on numerous occasions, created opportunities for rampant abuse by short sellers.