As a retail investor, I am concerned about the fairness of the current financial system. Having read many theoretical posts on r/Superstonk about the economy and doing my own research, I believe that more regulation on shorting is necessary in order to avoid the unfair devaluation of companies and protect smaller companies from its effects. In particular, more needs to be done about Fail-to-Delivers and synthetic shares to reduce the power that Market Makers and Hedge Funds have in determining the value of a stock on the market.

Hello FINRA, This is my comment for 21-19, regarding short positions. As I see it, the current US market is full of fraud which preys on the working classes, with our regulatory agencies being complicit. They are complicit through their inaction, with years of unchecked fraud, and market manipulation. It has been discovered that naked short selling by large hedge funds like Citadel and Susquehana has been allowed to happen with impunity.

This needs quick implementation so added transparency can give investors faith in FINRA as a reporting agency.

There is a lot covered here, it is obvious that some steps toward better transparency are at work. The simple fact of the matter is that there systemic issues with the creation of shares to borrow based on future volumes, failures to deliver, and shorting in general. While appreciated, and needed, the solutions to these do not lie in the resolution of transparency alone. Removing the capability to generate future transactions to borrow from, use for offsetting failed to deliver positions, and in general affecting the stock price negatively needs to be resolved.

Short interest need to not be self reported. There should be investigations every day or at least weekly to see how these hedge funds and market makers are influencing stock prices. Naked shorting is a disgusting practice that has caused economic crashes in the past. We need to learn from our past mistakes. The formula for calculating short interest needs to be fixed to show the actual number of short contracts as well.

When reporting short interest can be skewed through a loophole, this needs to be addressed. When short sale restrictions are enacted as a safety for a volatile stock, but overridden through a mysterious, unregulated exchange: this needs to be addressed. When asset managing/ trading firms have access to order flow prior to retail investors, and can systematically alter a stocks natural and organic movement: this needs to be addressed.

The Reporting of Loan Obligations as Short Interest. Theory suggests that some participants are borrowing shares from ETF's to cover their existing short interest. This only results in the same exposure continuing to exist elsewhere in the market, in effect, the short position has not been closed, but rather, is moved off the books which affects the integrity on both ends of the affiliate program.

I think retail is extremely desirous of seeing more frequent reporting and as much of that made publicly available as possible. At least of a weekly or bi-weekly basis. I believe the currently attempted short squeeze is bring to light that lack of transparency is being used to commit fraud and establish predatory roles against companies. The watering of stock has been an issue for nearly a century. It would be financially irresponsible to not increase regulation in these regards.

I strongly support stricter reporting requirements on short positions held by market makers and prime brokerages. It is increasingly necessary that FTD information be presented to the public as a way of not only limiting abuse of the FTD system, but also to reveal obfuscated information that is not readily available to the market and is often times concealed or miscategorized in reporting.

As a self-regulatory conglomerate it is beyond the reasoning of a "retail" investor as to why such ordinances do not already exist. The SEC itself has proclaimed naked-short selling to be a well established predatory and dangerous practice that undermines the free-market operations of millions of non-institutional investors who cannot play by the same rules. In addition to the regulatory capture here, it should be seen as important for FINRA to also enforce penalties in accordance to the scale of their misdoings.