Hello, I wholeheartedly support FINRA's step toward a slightly more transparent system. FINRA requests comment on whether FINRA should publish on the FINRA website short interest data for all equity securities (listed and unlisted). • Yes, absolutely all short interest data should be published. FINRA requests comment on whether the potential short interest enhancements discussed above would be equally beneficial for both OTC equity securities and exchange-listed equity securities.

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 nothing but 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 hedgefunds 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.

Recent market activity involving GameStop stock has shed light on misbehavior by hedge funds and other financial institutions involved in a practice called naked short selling. Though naked short selling was made illegal after the 2008 financial crisis, loopholes exist that allow for this practice to continue. (More details here: https://www.investopedia.com/terms/n/nakedshorting.asp). This includes fraudulent activity involving Shorts, Borrowed Shares, and Failures to Deliver.

First, there is no rule that can be put in place where the repurcussions are fines. Fines are a cost of doing business. Period. The street always makes far more money illegally then they pay in fines. 150% minimum fines. Now, that said, self reporting is a joke. We have the systems and technology available to ensure trades are marked correctly, that they are delivered adequately, not rehypothecated, and accurately reported. We should have 100% free, 100% accurate long vs short data on every stock, every day. Absolutely NO exemptions for any market participate, for any reason.

Anyone who has looked at the derivates market for $AMC and $GME knows that short interest is being aritfically brought down by the use of these options strategies. If the short interest was really as low as being reported by FINRA and others, we would not have outrageous borrow rates and a continuing avalanche of FTD's. When will we have transparency in our financial markets? "Synthetic Short Positions: In addition, FINRA is considering requiring firms to reflect synthetic short positions in short interest reports.

I approve of the general sentiment and direction discussed here. Increased reporting depth and frequency in these areas will create a better view of market for FINRA and will allow more granular analyses and understanding of potentially challenging issues and situations facing the market and investors. Knowledge through transparency is key to healthy markets

Creating synthetic shares is the same as counterfeiting. Put some teeth in your fines. Right now, the fines are so small, it's just a cost of doing business to these big companies. Do better at investigating naked shorting and up the fines. All shorting, no matter what exchange, should be reported and made public. Get rid of dark pools. And for pete's sake, it's 2021. Why isn't settlement immediate or at least by end of business?

Please explain why naked short sale reporting has been allowed so many "Fail To Deliver's" for over 20 years and no one from any government agency has done anything about it? If the economy fails because of this regulatory neglect who will pay for the clean up?

Simply put, Short Sellers have for decades made the argument that disclosing their position makes them a target for Short Squeeze. However, they in many cases target legitimate companies with the sole purpose of attempting to "shake out" longs to make a profit. This is not the intended use or purpose of allowing short positions, which as I understand it is as a way to address fraudulent statements, find a companies true fair value or transfer of monies when a company is struggling / failing.