Any data that is communicated publicly should be communicated in the most efficient manner possible. In a industry where data is considered to be so valuable that firms were willing to spend millions of dollars to have their fiber optic cable runs as close as physically possible to the exchanges so they could get a timing advantage, the short interest report being collected only a twice a month and distributed up to 12 days later is like finding out the asteroid hit 12 days later.

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to the edge of disaster, in large part due to systemic risk developed under the regulatory authority of FINRA's outdated short interest reporting policy.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

I am commenting in regards to particular aspects of FINRA 21-19, which I do support and believe should have been enacted long ago. Undoubtedly, the public’s faith in the United States market has been diminishing following the many preventable financial crises that have occurred in the past. The ongoing state of the market from retail investors points of view, frankly appears broken and has failed to manage systemic risk in the interest of the public, rather FINRA’s ridiculous short interest reporting policy has only benefited everyone but the average American.

It is ludicrous to expect any self-reporting method of counting short positions to be anywhere near reliable. Organisations engaged in industrial scale naked shorting will obviously not tell the truth about their positions, especially when the fines for mis-reporting are a tiny fraction of the profits they can make. The only trustworthy method of counting shorts would be to count the shares in circulation and subtract that from the number of shares that ought to be in circulation.

The arranged financing programs absolutely need to be reported as in this proposal regardless of possible “costs” anticipated. How else will we know what baskets of complex TRS type swaps contain the shares we rightfully own but have been hidden so as to hide FTDs.

" Publication of Short Interest for Exchange-listed Equity Securities" Why are firms are currently allowed to hold any unreported open short positions? In the OTC market, one firm's large short position could potentially destroy a company. " Content of Short Interest Data" The more data points you collect and publish, the better. A free and fair market means transparency for everybody. There's no reason firms should have access to every dimension of information, while they themselves remaining vague.

FINRA, you have big name institutions that have in the past been found violating regulations on how to properly mark a short as short instead of long, how to properly report information, and how to properly manage it. In a free and transparent marketplace, every institution should have their cards on the table. If they want to invest, they should report it. If they want to short, they should report it. Naked short selling is illegal, yet reporting short positions at all is not something considered necessary? Do you seriously need a comment to point out how backwards that is?

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.

More transparency in short positions is necessary for a fair market. There are currently too many methods of obscuring the real short interest of certain securities which creates an unfair environment for retail investors. FINRA should make more information about short sales public as well as investigate further into how synthetic shares are being created and hidden.

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.