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John Scariano Comment On Regulatory Notice 21-19

Short positions should be reported daily. FTD data reported daily. No more hiding behind walls of lag time. Reporting needs to be mandatory and verifiable, not merely self-reported. Punishments for non-compliance or falsification need to be much more severe and timely. Short reporting needs to also include the level of options sales that are naked. Naked Options produce synthetic shares and should be highly scrutinized.

Brian Babin Comment On Regulatory Notice 21-19

Eliminate dark pools Fines should be greater than the profit hedge made from the illegal activity Jail time is needed for market manipulation. Short positions should be forcibly closed out if illegal market manipulation is found and trading rights of those involved should be revoked. Shorting taking place in the dark pool needs to be disclosed to the public. If an institution buys shares in the dark pool and then dumps (sells) those same shares on the public exchanges to tank the price, this should have to be reported. Fail to Delivers should be reported to the public as well as Finra.

Regulatory Notice 21-27

Executive Summary

FINRA is making available updates to interpretations in the Interpretations of Financial and Operational Rules that have been communicated to FINRA by the staff of the SEC’s Division of Trading and Markets (SEC staff). The updated interpretations are with respect to Securities Exchange Act (SEA) Rules 15c3-1 and 15c3-3. 

Questions concerning this Notice should be directed to:

Christen W. Comment On Regulatory Notice 21-19

A. Providing short interest information to the public for free is a requirement to ensure the retail public's trust in the market. Without access to this information, the average retail investor is at a huge disadvantage when it comes to making trading decisions. Finra should take charge and publish this information daily, so retail investors can make timely decisions about their trading strategy and not have to guess based on data that is two weeks old by the time it is released.