I'm writing to request more transparency, fairness and accountability in our financial markets, as all of us rely on our regulatory entities for that assurance. There are some things that are of particular interest to me: 1. Transparency of Buy/Sell orders in the market as a whole, including but not limited to OTC/ATS off market trading. 2. Information market makers have when it comes to filing for a short position should be made known to everyone, including retail traders. 3. Short positions should be covered by everyone at close of day, no more T+ non sense. 4.

On this issues presented, my comments are: Short Interest Positions: I feel that short interest positions should be reported as all other positions are reported. There are videos of former hedge fund managers(Jim Cramer) admitting that psychological manipulation and misinformation are essential tools for a hedge fund to create narratives in the media for the purpose of manipulating a stock. Knowing who is to profit from such narratives would greatly assist the market in finding the correct value of a security despite efforts to undermine its value. Also, Shorting should be limited.

Just speculation but I’d look at dark pools. We’re seeing 60-71% volume of AMC trading there. Would it be possible to have have someone purchase a bunch of long AMC shares in a dark pool. Then have someone like say citadel buy them in the dark pool for a slightly larger price just to dump in them in the market at open to discourage people from investing in AMC. Seems like manipulating to me.

Dark pools should be monitored and enforced with sanctions (suspensions) to prevent abuse which adversely impact true equity price and unfairly advantage market makers. FTD need to be enforced and not delayed with swaps and/or complicated moves not afford to the public. Naked Shares should be banned to prevent fraudulent resale of equities.

If you read the Regulatory Notice 12-38 regarding FINRA's Short-Interest Reporting Rule, you'll come across this particularly relevant question in the FAQs. Q7. How should a firm reflect fractional shares in its short-interest reports? A7. If a firm has a fractional short-interest position (e.g., 125.6 shares), it should truncate the position to reflect a whole number when reporting such positions to FINRA pursuant to FINRA Rule 4560, instead of rounding the position up or down. For example, firms should report short-interest of 125.6 shares in XYZ as 125 shares.

Having dark pools that trade off market it’s just for manipulation and having platforms like citidel connect that doesn’t even report to you is insane. Auditing these market makers to see how many naked shorts they hold should be a top priority.

Short interest should not be self reported. I would like to see audits take place to check for shorts hidden in options. I would like to see a requirement to have all synthetic short positions and Fail to Delivers reported daily, making it public knowledge. Along with transparency, it should be publicly reported when institutions are margin called and when they close out their short positions.