I am writing as a humble retail investor. Recent events and research have demonstrated that the entire securities market is built around big players taking money directly from retail investors and legitimate corporations who have zero recourse. The current system for reporting short sales is laughably ineffective. It is completely obscured from retail traders, intentionally preventing free trade based on equal knowledge. Naked short sellers are able to collude to drive down the price of a stock with a limitless supply of fraudulent shares.

Short selling and rehypothecation has been used to the detriment of retail investors and is threatening to destroy the entire market structure if left unchecked. Stricter reporting of positions, including naked shorts should be happening already. Brokerage firms, market makers, and other financial institutions were never meant to have as much control over the financial markets as they currently hold.

Short Interest reporting AND ENFORCEMENT needs to improved at multiple levels. No hedge fund or investor should be given an excuse to hide what they are doing or to delay reporting or masking it in creative work arounds. 21-19 is a vast improvement. As a retail trader for decades >40 years. It’s about time more reporting and penalties for institutions and investment funds are ratcheted up. Please do not let the big guys voice be louder and more important than mine.

I want to see full and immediate transparency for short interest and FTDs. This is a needed requirement if this market is ever going to be free and equal.

21-19 is long overdue and absolutely necessary, my prior comment was rescinded

As a retail investor, I believe all of the proposed changes should be enacted. Transparency is a requirement for our markets to remain fair and free. Gamestop had a short interest of 140% of the float at one point in December 2020/January 2021 which lead to the WallStreetBets short squeeze and subsequent trading restrictions because of systemic risk. If the short interest had been reported on a more frequent basis, this "idiosyncratic" systemic risk would have been more visible and could have been tackled in a different way other than restricting trading.

Accurate short sale tracking is important, but it’s only as useful as the information given on dark pool activities. Dark pool existence, and how those exchanges are able to integrate shares into major exchanges is beyond fraudulent. I appreciate your efforts, but share selling will never be put into check until dark pools are eliminated.

As one of the biggest regulating bodies within the overseeing of the stock market, Finra should strive to have a way more transparent, thorough and demanding framework for reporting short positions. You admit in your proposal that the extent of which many of these methods are being implemented in the market - are unknown. As the framework stands today, institutions that profit from short selling are almost incentivised to hiding their short positions, as there are multiple methods for doing this LEGALLY.