Hello and good morning/afternoon/evening. I'd like to start by thanking you for being open to comments from retail traders. 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.

I'm a retail investor, of the style that invests my meager retirement in ETFs and other low-risk vehicles. I've recently become more interested in managing my own IRA and such, in part due to the fervor surrounding GME and other tremendously short sold stocks. This interest let me to reading extensively about short interest, reporting, FTDs, and the options techniques used to "hide" short positions from the lit market. At one point, during the January runup initally with GME, for a short while GME was >100% short.

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to the edge of disaster, in large part due to systemic risk developed under the regulatory authority of FINRA's outdated short interest reporting policy.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

The time is now to fix this broken system. I am not leaving.

The confidence in the US market is waning and will collapse in time. For too long FINRA's out-dated short interest reporting policy has allowed malicious activities to continue with little to no oversight in the form of abusive and extraordinary over-leveraging of short positions. Many of the policies mentioned in Regulatory Notice 21-19 address the short interest ineffective reporting, yet, they also leave significant holes that compromise the entirety of 21-19's purpose, almost as if they were left this way.

If there was more transparency into short seller positions paired with the proposed enhanced reporting practices it could encourage a more fair market for all investors, not just those largest participants. When attempting to do research into short positions into some companies I had a long position in, the information was so sparse, and vague to say the least, you could not accurately assess the effect it was having on price discovery. We need short sellers need to be more closely monitored to have a fair and balanced market we can have confidence in.

Retail investors are losing faith in the market. I urge you to take action to regularly disclose all short positions, whether genuine or synthetic (through married options, for example) on a weekly basis. This will allow individual investors to make more informed decisions about which companies they should invest their money in and will resolve the question of whether bad actors are using illegal "naked" short sales to manipulate security prices.

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.

To whom it may concern: I have grave concerns that the goals of the 21-19 rule change have too many loopholes and will not meet the stated goals of the effort. In fact, FINRA's minimal efforts at preventing ongoing FTD violations and options and swaps manipulation that circumvents REG SHO and T+2 requirements has led me to believe that FINRA is unable to be trusted as a Self-regulating Organization, and I will be informing my Congressional delegates of that opinion and strongly urging a return to direct government oversight.

The ways in which hedgefunds, family offices, and institutions are able to hide their naked short positions, whereby effecting an inaccurate short interest %, means that this isn't a level playing field. Force them to disclose ALL positions so that I, a retail investor, may choose to invest my money in a responsible way.