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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.