I am encouraged that you are considering changes on the subjects of Short Interest Position Reporting Enhancements and Other Changes Related to Short Sale Reporting. These changes are will open the way to fair market operations. In the current environment the technology and information for market operations is far superior compared to what is available to regulators and ultimately the public. That tech is being abused in an aggressive manner which is in turn creating blind risks for the investing public.

I am in favor of these proposed rule changes. Specifically the disclosing of synthetic positions. It is vital that this information be made available to combat predatory trading practices. Practices that artificially destroy businesses and lives. If we cannot eliminate the loophole that allows for synthetic naked shorting, getting as much information made public is the next best thing. Perhaps it can save many businesses from closing and jobs from disappearing.

Hello FINRA, I saw you are looking for comments on 21-19, regarding short positions. As I see it, the current US market is full of fraud, with the regulatory agencies being complicit. They are complicit through their complacency, with years of unchecked fraud and market manipulation through naked short selling by large hedge funds like Citadel and Susquehana being allowed to happen with impunity. The SEC and FINRA have known about this illegal counterfeiting practice for many years, with nothing being done to rectify the illegality of the market conditions. Naked shorting is illegal.

Short interest reporting by all of these entities should have complete transparency. Failures to report on possible FTD’s, never delivering those shares or marking short positions as long should result in repercussions equal to the actions. Small fines or as they can be referred “the cost of doing business” for some of these funds or entities are unacceptable. Reporting should be even more frequent as streamline the process of collecting accurate data.

All short positions SHOULD BE disclosed. Any stock lending should be subject to daily reports. Keeping the data hidden hurts retail investors, as the price is being affected by things they are unable to see.

My concern with shorting a stock is the impact that action has on the company. By shorting 100% of a company's stock (or more!), the stock may drop to a low enough price that the company can't survive regardless of the underlying value. I would suggest a cap on the percentage of a company's outstanding shares that can be shorted, say 60%. This would allow the investor the ability to short while not driving the company out of business by doing so.

It will never be a fair playing field if shorts are not disclosed and we will look like frauds to the entire world. Naked short sellers deserve prison.

Of particular interest is the section on Synthetic Short Positions. It seems that approved participants can use synthetics to improve market liquidity, but it also creates a problem of diluting the stock when the shorts fail to deliver. Would position reporting also help to track FTD's better and implement some regulation to have those failures sufficiently resolved before more synthetics are allowed to be created? I understand this could squeeze the shorts a bit, but it seems to make sense in terms of correctly managing scalability.