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.

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to the edge of disaster, in large part due to systemic risk developed under the regulatory authority of FINRA's outdated short interest reporting policy.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to the edge of disaster, in large part due to systemic risk developed under the regulatory authority of FINRA's outdated short interest reporting policy.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

Thank you for your time. Currently as it stands, there is too little information in true short positions. With a market makers ability to create synthetic shares for “liquidity”, at some point the true positions need to be accounted for. If a bank, a market maker, and or other parties can hide positions through layered securities like CDOs or swaps, there is no benefit to the market, only the entities on the short side benefit. It doesn’t show a true borrow fee for short interest, and is already a sign of two entities working in tandem, possibly in collusion.

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.