The FINRA 21-19 filing is a long overdue step in the right direction. However, given the current rules set in place, which allows prime brokerages to give their clients, hedge funds, an ability to essentially circumvent any short position reporting through what they call 'short arranging products' or 'arranged financing programs', the regulations proposed in FINRA 21-19 will most certainly not have the desired effect. FINRA, SEC and other regulatory bodies absolutely MUST give a hard look on these programs, as they are a threat to U.S markets' stability, transparency and integrity.

My investment experience has been limited to the last few years, so I can’t pretend to have a comprehensive understanding of every law, rule, guideline, parameter, and standard operating procedure that financial institutions operate in accordance with. However, I can say with certainty that neither do major financial institutions responsible for the behavior of our markets. If the role of a market maker is to provide liquidity for our markets, then a ‘failure to deliver’ directly conflicts with their core responsibilities.

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to the edge of disaster, in large part due to systemic risk developed under the regulatory authority of FINRA's outdated short interest reporting policy.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

It is critical for the restoration of both the stability of the US markets and the confidence of the investors within it that any and all regulation changes regarding short interest reporting be effective in every known circumstance where effective short positions, synthetic or not, can go unaccounted for for any length of time greater than any other short position reporting deadline.

FINRA 21-19 is something that our "free and fair" markets desperately need. For too long, retail investors like myself have been kept in the dark. It has become more clear than ever that our markets are teetering on a sword's edge due to a lack of transparency and accountability. - Account-level Position Information: Alternatively, FINRA is considering requiring firms to report (for regulatory purposes only; not to be disseminated publicly) short interest position information with more granularity by reporting at the account level for all equity securities.

It is critical for the stability of the US markets and investor confidence that short interest reporting covers every known circumstance where short positions -- synthetic or not -- exists. THE POLICY SHOULD BE COMPREHENSIVE SO THAT NO SHORT POSITION CAN GO UNACCOUNTED FOR. Reporting gaps must be bridged. Policy must be consistently enforced. This is long overdue.

To whom it may concern at FINRA, I am not a very eloquent person, so please note that I have taken bits and pieces of comments and copy/pasted them. Just because I have not articulated these thoughts myself, does not mean that I am any less passionate about the proposed rule changes. Since beginning my journey as a retail investor and learning more about our financial systems I have lost complete faith in the US markets. I truly, deeply believe that market abuses (such as naked short sales) by hedge funds and market makers has set humanity back.

To whom it may concern, FINRA 21-19 will be an effective change that should've been implemented long ago to end the systemic risk involved in the current inadequate state of short-interest reporting. American and global investors are looking at the state of the American market and find themselves uncertain about the validity of the reported numbers when various short positions are unaccounted for because of an endless array of technicalities. This concern is real and should be of the utmost concern to FINRA as investors will otherwise seek more trustworthy alternatives.

Given the significant damage Short Interest can have on a smaller company, I am eager to have better reporting tools to help these smaller companies protect themselves from the aggressive larger players in the economy. Having bad data is the last help being given to these large hedgefunds, so we request frequent accurate data to better level the playing field for all investors rich or poor. The system now only helps the rich.

FULL TRANSPARENCY/ NO MORE LOOPHOLES Investors demand an end to the systemic corruption and crime that is plaguing our markets through un-regulated short selling that siphons real value from companies and investors and PREVENTS proper price discovery. Direct Registering (DRS via a transfer agent) shares is currently the ONLY way to escape the rampant fraud and the ineffective, unenforced regulations in our markets.