Retail trader here I believe FINRA 21-19 is long over due the integrity of the United States market depends on it and here's why. The policies mentioned in Regulatory Notice 21-19 address the general breadth of exploitable and ineffective reporting, they leave significant specific gaps that could compromise the entirety of 21-19's purpose.

Although I do believe 21-19 will be beneficial towards the progression of building a free and fair market structure, I do not have faith in FINRA's ability to self regulate the parties of Wall Street. By just acknowledging these problems, it does not solve them. Action must be taken. For years, these criminal enterprises have operated in tandem with the entities that regulate them, allowing for mass undertakings of fraud and misreporting that have wreaked havoc on the United States and global financial markets.

This ability by hedge funds and market makers to indiscriminately and malignantly sell short in multiple ways to hide short interest hurts the market for retail. I’m sure if the entire retail sector of the market understood the various ways short interest is hidden and how their long investments were used against them to reduce the value of their investments, they would never invest in the market ever again. The market isn’t free nor is it fair. Short interest reporting needs to be immensely detailed and completely transparent, exploring all of the ways short interest is hidden.

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to the edge of disaster, in large part due to systemic risk developed under the regulatory authority of FINRA's outdated short interest reporting policy.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 close the dark pools. That and naked shorting are unfair to retail investors and the companies that are going out of business.

Entities which are found to be breaking the law need to be punished for doing so. Failing to respond to the actions of malicious actors leads to instability in the system, an imbalance of power when there should not be one, and a loss of trust in the viability of the system itself. The punishments must be sufficient to discourage future attempts and breaking the law. If breaking the law and paying a fine is more profitable and the only consequence for breaking the law is that fine, why would anyone pursuing profit not break the law?

Regarding TSO- It is irresponsible to allow trading over and above the TSO. This amounts to trading synthetic shares that do not exist and allows market makers to game the system. Not having accurate and timely TSO information and control in a market where brokers have the ability to perform thousands of trades per second is unacceptable and amounts to a failure in duty. On market makers who act as brokers and PFOF originators or in concert with; there has never been a more blatant conflict of interest than allowing a firm to act as market maker, broker, and hedge fund.

I would like to begin by thanking you for taking our comments. I have a few general comments before I attempt to address any of the points raised in your "Background and Discussion" and "Request for Comments" sections. To summarize my position: how is it possible that in an era of rapid trading in which computers execute thousands (or more) trades per second on any given security, that it is not possibly to simply and succinctly state the exact number of short positions taken against a given security (including synthetic shorts)?

1) make sure you receive correct data. 1a) if you don't, somehow make sure they do in penalties, that isn't pennies for short interest positions. Either make them relieve their position or ban them for trading for some time. 1b) don't let them self report giving them the option to lie. 2) ban dark pools. It does add liquidity, somehow. But at what cost? Especially with payment for order flow, these companies can front run any retail investors, without affecting market price, before the end of day. I want market transparency and fairness.