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Jim Littler Comment On Regulatory Notice 21-19

1/ Synthetic short positions should be included in short interest reports. 2/ REGSHO- information of allocations of FTD's should definately be updated. daily report of FTD's should be mandatory.3/Publication of short interest for Exchange listed Equity securities to include both OTC & Exchange should also be implemented. 4/ Rule 4560-Loan obligations regarding short position closures. Please change this to include the shares borrowed through an arranged finance deal.

Bennet Comment On Regulatory Notice 21-19

I fully support this proposed rule change and additional rule regarding short position reporting. Additional rules to protect investors, especially retail investors, should be explored on this topic as well as other issues such as order flow prioritization, block share lending, and ability to dictate exchanges for orders to be sent to. How is it possible for >50% of the daily trading volume to be done on private exchanges with no price reporting? How can these exchanges limit who is eligible to participate on them?