Skip to main content

For updates and guidance related to COVID-19 / Coronavirus, click here.

Regulatory Notice 21-19

FINRA Requests Comment on Short Interest Position Reporting Enhancements and Other Changes Related to Short Sale Reporting

FINRA has extended the comment period to September 30, 2021.

Comment Period Expires: August 4, 2021

Summary

FINRA is requesting comment on potential enhancements to its short sale reporting program.  FINRA is considering: (1) modifications to its short interest reporting requirements (Rule 4560); (2) a new rule to require that participants of a registered clearing agency report to FINRA information on allocations to correspondent firms of fail-to-deliver positions; and (3) other potential enhancements related to short sale activity. FINRA believes that these potential changes could improve the usefulness of short sale-related information to FINRA, other regulators, investors and other market participants.

Questions regarding this Notice should be directed to:

  • Yvonne Huber, Vice President, Market Regulation Department, at (240) 386-5034 or by email; or
  • Racquel Russell, Associate General Counsel, Office of General Counsel, at (202) 728-8363 or by email.

Questions regarding the Economic Impact Assessment in this Notice should be directed to Lori Walsh, Deputy Chief Economist, Office of the Chief Economist, at (202) 728-8323 or by email.

Action Requested

FINRA encourages all interested parties to comment on this request for comment. Comments must be received by August 4, 2021.

Comments must be submitted through one of the following methods:

  • online using FINRA’s comment form for this Notice;
  • emailing comments to [email protected]; or
  • mailing comments in hard copy to:

    Jennifer Piorko Mitchell
    Office of the Corporate Secretary
    FINRA
    1735 K Street, NW
    Washington, DC 20006-1506

To help FINRA process comments more efficiently, persons should use only one method to comment.

Important Notes: Comments received in response to Regulatory Notices will be made available to the public on the FINRA website. In general, comments will be posted as they are received.1

Before becoming effective, a proposed rule change must be filed with the Securities and Exchange Commission (SEC) pursuant to Section 19(b) of the Securities Exchange Act of 1934 (SEA).2

Background and Discussion

FINRA currently collects short sale-related information from firms to support FINRA’s oversight of member compliance with Regulation SHO3 and other short sale obligations, and to provide market participants with insight into short sale activity and position information. Pursuant to FINRA Rule 4560 (Short-Interest Reporting), firms are required to report to FINRA their aggregate short position in each equity security twice a month.4 As described further below, the short interest data collected by FINRA includes the reporting firm’s current aggregate short interest position for the security and any short position changes at the firm since the prior reporting period, among other things. For over-the-counter equity securities, FINRA aggregates and publishes the collected short interest data (aggregated across all firms, per symbol) on the FINRA website along with additional FINRA-calculated metrics relating to short sale activity in the security (e.g., days to cover5).6 For exchange-listed securities, FINRA provides the reported short interest data to the applicable listing exchange for processing and publication.7  

FINRA is considering whether amendments to its short interest reporting and dissemination program would be appropriate to improve the regulatory and public utility of the information. FINRA also is considering whether any changes to other aspects of its short sale regulatory program would be beneficial, as discussed below.

A. Publication of Short Interest for Exchange-listed Equity Securities

FINRA Rule 4560 requires firms to report short positions in all equity securities (other than Restricted Equity Securities) to FINRA. Thus, FINRA members are required to report short positions in both OTC equity securities and exchange-listed equity securities. However, FINRA currently only disseminates on the FINRA website short interest information for OTC equity securities. For exchange-listed securities, FINRA provides the reported short interest position information to the applicable listing exchange for processing and publication. Exchanges historically have handled the publication of short interest data for their listed securities, even after short interest reporting for all equity securities was consolidated through FINRA in 2008.8

FINRA is considering consolidating the publication of short interest data that is reported to FINRA for both listed and unlisted securities. If FINRA were to make this change, short interest files for all equity securities would be made available free of charge on the FINRA website and would not require changes to firms’ reporting requirements. In addition, if this change was made, the below potential changes to the content and timing of publicly disseminated data would apply to listed and unlisted securities. 

B. Content of Short Interest Data

FINRA receives short interest data from members on a firm-by-firm basis and subsequently aggregates the information by security to create the disseminated data files. FINRA is considering changes to the data fields firms are required to complete. 

As discussed above, FINRA’s website publication of short interest data currently is limited to non-exchange listed, OTC equity securities and includes the following fields:

  • Security name
  • Symbol
  • Settlement Date
  • Market (i.e., OTC equity securities)
  • Current aggregate short interest position for the security across all firms
  • Previous aggregate short interest position for the security across all firms
  • Change in short interest position since the prior reporting period (number of shares)
  • Change in short interest position since the prior reporting period (percentage)
  • Average daily trading volume for the security
  • Days to cover9
  • Revision Flag10

FINRA is considering the following changes to reported and disseminated short interest data.11 In some cases, FINRA also is considering whether the additional data points proposed to be collected should be disseminated publicly or used only for regulatory purposes. 

  • Proprietary and Customer Account Categorization: FINRA is considering requiring firms to segregate the total reportable short interest into two categories—short interest held in proprietary accounts and short interest held in customer accounts. Specifically, in addition to reporting the total short interest in a security, firms also would be required to specify the short interest held across all proprietary accounts and across all customer accounts (for both retail customer and institutional customer accounts) for each equity security as of the close of the designated reporting settlement date. FINRA believes that this information would provide beneficial regulatory information regarding the type of market participant that accumulated a short interest position (i.e., a firm or a non-broker-dealer customer).  
  • Account-level Position Information: Alternatively, FINRA is considering requiring firms to report (for regulatory purposes only; not to be disseminated publicly) short interest position information with more granularity by reporting at the account level for all equity securities. Account-level short interest position information would provide FINRA with insight into the identity of the individuals or entities that accumulated concentrations of large short interest positions, which FINRA would use to enhance its reviews for compliance both with SEC Regulation SHO and FINRA’s short sale rules. 
  • Synthetic Short Positions: In addition, FINRA is considering requiring firms to reflect synthetic short positions in short interest reports. For example, enhanced short interest reporting could include synthetic short positions achieved through the sale of a call option and purchase of a put option (where the options have the same strike price and expiration month) or through other strategies. FINRA believes this information would assist FINRA in understanding the scope of market participants’ short sale activity,  specifically regarding the use of less-traditional means of establishing short interest. 
  • Loan Obligations Resulting From Arranged Financing: FINRA understands that members may offer arranged financing programs (sometimes called “enhanced lending” or “short arranging products”) through which a customer can borrow shares from the firm’s domestic or foreign affiliate and use those shares to close out a short position in the customer’s account. FINRA is considering requiring members to report as short interest outstanding stock borrows by customers in their arranged financing programs to better reflect actual short sentiment in the stock. 
  • Total Shares Outstanding (TSO) and Public Float: FINRA also is considering including in FINRA-disseminated short interest data, where available, the TSO and public float for securities. FINRA would obtain this information from a third-party source and include it in disseminated information; therefore, this change would not alter firms’ reporting requirements. FINRA believes disseminating a security’s TSO and public float would provide investors with contextual information regarding the relative size of the aggregate short position in the security.
  • Threshold Security Field:12 FINRA is considering including in FINRA-disseminated short interest data a new field that would indicate if the security is a threshold security as of the short interest position reporting settlement date. This change would not alter firms’ reporting requirements. FINRA believes that a security’s status as a threshold security could be useful to investors and other market participants in evaluating an investment decision, and that consolidating this information into disseminated short interest data simplifies the process of obtaining this information for users of the data. 

C. Frequency and Timing of Short Interest Position Reporting and Data Dissemination

Members currently must submit short interest reports to FINRA twice a month and reports are due to FINRA by 6:00 p.m. ET on the second business day after the reporting settlement date designated by FINRA. FINRA is considering requiring firms to report short interest data to FINRA more frequently. Specifically, FINRA is considering reducing the reporting timeframe to daily or weekly submissions and, to enable FINRA to disseminate the collected information to the marketplace on a timelier basis, such reports also would be due to FINRA in a shorter timeframe following the applicable settlement date. For example, if FINRA were to require daily submissions, short interest reports could be due by 6:00 p.m. ET one business day after the designated reporting settlement date, and for weekly submissions, short interest reports could be due by 6:00 p.m. ET one business day after the weekly designated reporting settlement date (instead of the current requirement of two business days after the designated reporting settlement date).13  

FINRA also is considering reducing the FINRA processing time involved in disseminating short interest data. Currently, FINRA disseminates short interest data for OTC equity securities on the FINRA website seven business days after the designated settlement date, which is five business days after the reports are due from member firms. FINRA is considering reducing this processing time. The proposed reduction in FINRA processing time could apply where firms report short interest to FINRA on a daily or weekly basis, as described above, and also could apply to the current twice a month reporting cycle (with or without a reduced firm turnaround time).

Increasing the frequency and timing of reporting and disseminating short interest data would provide FINRA, other regulators, investors and other market participants with a more current view of short interest information, better inform investors’ and other market participants’ investment decisions, and provide more timely information to FINRA for regulatory use.

D. Information on Allocations of Fail-to-Deliver Positions

Regulation SHO permits a member that is a participant of a registered clearing agency to allocate a portion of its Rule 204 fail-to-deliver position to another broker-dealer based on that other broker-dealer’s short position.14 FINRA is considering enhancing its short sale reporting program by adopting a new rule to require members to submit to FINRA (for regulatory purposes only; not for public dissemination) a report of daily allocations of fail-to-deliver positions to correspondent firms pursuant to Rule 204(d) of Regulation SHO. 

The proposed allocation report may include the following fields:

  • Security
  • Identity of correspondent firm
  • Amount allocated to correspondent firm (number of shares)
  • Trade date(s)
  • Allocation Date
  • Close out Date
  • Applicable close out obligation (T+3, T+5 or T+35)

This information would provide FINRA with important supplemental information in support of its Regulation SHO surveillance program. Currently, when there has been a fail-to-deliver, FINRA initiates an inquiry with the clearing firm requesting information on whether the fail-to-deliver has been allocated to a correspondent firm and, if so, the identity of the correspondent firm. Obtaining daily information on fail-to-deliver allocations would allow FINRA to directly identify the member that is responsible for a close-out obligation (without first requesting this information from the clearing firm), and, therefore, would allow FINRA to conduct more efficient investigations.

Preliminary Economic Impact Analysis

FINRA has undertaken a preliminary economic impact assessment, as set forth below, to analyze the potential economic impacts, including anticipated costs, benefits, and distributional and competitive effects, relative to the current baseline, and the alternatives FINRA considered in assessing how to best meet its regulatory objectives.

Regulatory Need

The proposed short sale-related reporting enhancements would provide greater transparency regarding short sale activity. More current and detailed data can be of use to market participants who consider short interest when evaluating investment opportunities. It also would allow FINRA to monitor for compliance more efficiently with Regulation SHO and other short sale obligations.

Economic Baseline

Under current Rule 4560, firms report to FINRA the gross short interest in a security aggregated across all accounts twice a month. Firms have two business days after the settlement date to submit the reports. 

The data do not distinguish the type or identity of accounts with short positions. The data also do not reflect short positions that are achieved synthetically or loan obligations resulting from arranged financing. For OTC securities, short interest information is aggregated at the security level and then disseminated to investors five business days after the reporting deadline. This results in a seven-business day delay before investors have access to the collected short interest data. Investors who wish to know the short interest as the percentage of shares outstanding or public float, both of which are commonly used metrics that can be compared across securities, must look up the denominator elsewhere. Changes in short interest for OTC equity securities can be fairly large between settlement dates relative to the average daily trading volume in these securities. In comparing the short interest on the March 15, 2021 and March 31, 2021, settlement dates, 8,017 OTC equity securities had changes in short interest. The magnitude of the change in short interest for OTC equity securities amounted to 28 percent of the average daily trading volume for the median security but rises to 424 percent by the 75th percentile and 62,869 percent by the 95th percentile.15

For exchange-listed equity securities, bi-monthly short interest data is aggregated at the security level and provided to the relevant listing exchange that determines the content of the data it disseminates. Changes in short interest for exchange-listed equity securities between settlement dates can also be fairly large relative to average daily trading volume. In comparing the short interest on the March 15, 2021 and March 31, 2021, settlement dates, 10,027 exchange-listed equity securities had changes in short interest. The magnitude of the change in short interest for exchange-listed equity securities amounted to 26 percent of the average daily trading volume for the median exchange-listed security but rises to 60 percent by the 75th percentile and 192 percent by the 95th percentile.16

With respect to information on fail-to-deliver allocations, firms do not currently routinely report this information to FINRA. Instead, when there is a fail-to-deliver, FINRA contacts clearing firms for information on whether the fail has been allocated and, if so, to whom. On a median day in March 2021, 5,799 equity securities had outstanding fail-to-deliver positions.

Economic Impact

Publication of Short Interest for Exchange-listed Equity Securities

Although short positions in all equity securities are reported to FINRA, FINRA currently only disseminates short interest position data for OTC equity securities. Publication of data for exchange-listed securities is handled by the exchanges, which may also license this data for distribution by third parties.

Consolidating the publication of short interest data to include both OTC and exchange-listed equity securities on the FINRA website may make short interest data more easily accessible to investors and potentially at lower cost.

Members would not incur any direct costs associated with this change. However, some exchanges currently charge fees for access to or licensing for short interest data on their listed securities, and this revenue could be reduced if the data is freely available on the FINRA website. The decrease in revenue could potentially be passed on in the form of increases in other fees for other market participants.

If FINRA were to publish these data, the other potential changes to the content and timing of short interest data discussed below would apply to both exchange-listed and OTC equity securities. The broader applicability of these changes could affect the benefits and costs. FINRA requests comment below on whether it should adopt these changes and if any of the changes should apply differently to OTC and exchange-listed equity securities.

Content of Short Interest Data

Proprietary and Customer Account Categorization

Under current Rule 4560, firms report gross short interest in a security on an aggregated basis across all accounts. 

FINRA believes information on the type of market participant holding a short interest position would be useful in its oversight of Regulation SHO and other short sale obligations. This information may also be useful for market participants. While proprietary short selling by members is not necessarily for the purposes of liquidity provision, it may correspond to this category to some degree and, therefore be less likely to reflect negative sentiment in the stock. Below, FINRA requests information on whether dissemination of this information would provide useful information to the marketplace.

FINRA members would be required to make systems changes to report short positions categorized by the type of account. This would represent a fixed cost to FINRA members that report short interest. The ongoing cost and variable cost with respect to transaction volume of reporting short interest by type of account is expected to be minimal for firms as costs currently are incurred for existing short interest reporting. We request comment below on the costs associated with the proposed changes.

It is possible that the public dissemination of more granular data could discourage short-selling activity, which is an important mechanism for both efficient pricing and for liquidity provision.17 We also request comment on potential negative outcomes of making this information publicly available on an aggregated basis.

Account-level Position Information

Currently, short interest is reported by a firm on an aggregated basis across all accounts. By requiring firms to report short interest positions at the account level, FINRA believes it will obtain insight into the identities of individuals or entities with large short interest positions that would enhance its reviews for compliance with Regulation SHO and other short sale obligations. To obtain the full benefit of this data, FINRA is also considering possible ways to identify account holders across firms.

FINRA members would incur costs associated with making systems changes required to report short interest at the account level. The ongoing cost and variable cost with respect to transaction volume of reporting short interest at the account level is expected to be minimal as costs are currently incurred for existing short interest reporting but the volume of data reported would be substantially higher. The costs may be reduced if account-level reporting is only required for securities that meet a certain threshold of total short interest. We request comment below on the costs associated with reporting account-level information.

Synthetic Short Position

The sale of a call option and purchase of a put option with the same expiration date and strike price provides equivalent exposure to the price of a stock as a short sale. Despite this equivalence, this synthetic position does not currently create a short position that would be reportable under the current version of Rule 4560. The extent of use of this and other types of synthetic short positions is unknown.

A more expansive reporting requirement that captures synthetic short positions would allow FINRA to be better able to understand market participants’ short sale-related activity. As synthetic short positions provide equivalent exposure, information on them may also provide investors and other market participants with similarly useful information on negative sentiment. The benefits of this additional information may be limited by an absence of information on whether and to what extent the synthetic short positions are hedged. FINRA requests comment below on whether the proposed synthetic short position reporting requirement is appropriate and the scope of the types of strategies that should be reportable. 

FINRA members would incur costs associated with making systems changes required to identify synthetic short positions and include this information in short interest reports. The variable cost of reporting this information is likely to be minimal as costs are currently incurred for existing short interest reporting. We request comment below on the costs associated with the proposed changes. To the extent that market participants wish to avoid disclosure, they may respond to a new reporting requirement by instead taking similar positions that fall outside the bounds of the proposed definition of a synthetic short position. A synthetic short position reporting requirement with a broader scope than the sale of a call option and purchase of a put option with the same expiration date and strike price could potentially mitigate such avoidance.

Loan Obligations Resulting from Arranged Financing

When a customer closes-out a short position by delivering shares borrowed from a member’s affiliate, the customer acquires an obligation to deliver shares to the affiliate in the future. The exposure from this loan obligation is substantially equivalent to a short position but the loan obligation is not a reportable short position under the current version of Rule 4560. If customers can close out short positions by borrowing shares from unaffiliated lenders, those loan obligations would have the same economic equivalence to reportable short positions. We request comment below on whether firms have such programs.

Expanding the short interest reporting requirement to capture loan obligations resulting from borrowing shares through an arranged financing program would allow FINRA to be better able to understand market participants’ short-sale related activity and more fully reflect short interest sentiment. FINRA requests comment below on whether customers’ outstanding stock borrows through arranged financing programs should be reflected in short interest reports. 

FINRA members would incur costs associated with making systems changes required to identify loan obligations resulting from arranged financing. The ongoing cost and variable cost with respect to transaction volume of reporting this information is expected to be minimal as costs are currently incurred for existing short interest reporting. We request comment below on the costs associated with the proposed changes. To the extent that market participants wish to avoid disclosure and use arranged financing for this purpose, disclosure requirements for the resulting loan obligations could potentially shift some borrowing activity away from arranged financing.

TSO and Public Float

FINRA currently disseminates information on the current aggregate short interest in an OTC equity security in number of shares. The TSO or public float would provide investors and other market participants with additional context for use in understanding short interest information. Members would not incur costs in connection with this change.  FINRA requests comment below on whether including this information in the disseminated short interest position data would be useful to investors and other market participants.

Threshold List Field

FINRA currently distributes a daily list of OTC equity threshold securities. Including threshold security status in FINRA-disseminated short interest data would make this information more easily accessible and salient to market participants. Among other reasons this information may be relevant to investors, academic work has found that threshold securities tend to experience subsequent abnormal returns.18 Members would not incur costs in connection with this change. FINRA requests comment below on whether including this information in the disseminated short interest position data would be useful to investors and other market participants.    

Frequency and Timing of Short Interest Position Reporting and Data Dissemination

Currently, firms submit short interest reports twice a month with reports submitted on the second business day after the reporting settlement date. Information on the volume of short sales for OTC equity securities is released at a daily frequency, but short sale volume does not equate to short interest position information. Comerton-Forde et al. (2016) show that in Australia, where information on both short interest and short sale volume are disclosed at a daily frequency, the two metrics provide distinct information.19 Estimates of short interest at a daily frequency based on other sources such as securities lending data are available for purchase from vendors, but may be less accurate and are not freely available.

By increasing the reporting frequency to weekly or daily, reducing the time after the settlement date by which firms must report short interest to FINRA, and reducing the delay prior to public dissemination, FINRA and other regulators would have a more current view of short interest information for oversight of compliance with Regulation SHO and other short sale obligations. More frequently updated and current information on short positions may also be more useful to other market participants making investment decisions than the information available from FINRA today. The value of this information to market participants is demonstrated by the demand for estimates of daily short interest.

The magnitude of costs accommodating more frequent reporting with a faster turn-around time is unclear and would depend on the amount of labor involved. Changes in costs may result in changes in short selling behavior by firms or investors. We request comment on the costs associated with increased frequency and shorter timing for short interest reporting below.

It is possible that more frequent public disclosure of short interest positions could discourage short selling, which is an important mechanism for price efficiency and for liquidity provision.20 We also request comment below on potential negative outcomes of making this information publicly available.

Information on Allocations of Fail-To-Deliver Positions

When there has been a fail-to-deliver, FINRA currently must contact the clearing firm to learn whether the fail-to-deliver has been allocated to a correspondent firm and if so, to whom it has been allocated. FINRA would be able to conduct investigations more efficiently if daily allocation information was reported to FINRA. Member firms may also benefit from freeing up resources used to respond to inquiries about allocation to correspondent firms.

FINRA members that are participants of a registered clearing agency would incur costs associated with establishing and operating systems to report daily allocations to correspondent firms. The incidence of such costs could also potentially fall on other FINRA members whose trades are cleared by members directly affected by the reporting requirement if the cost is passed on in the form of higher fees. We request comment below on the costs associated with the proposed changes.

Alternatives Considered

No other alternatives beyond those discussed above were considered for the proposed amendments. However, FINRA also requests recommendations below on any additional short sale-related reporting changes that should be considered.

Request for Comments

As discussed above, FINRA is considering consolidating short interest data publication on the FINRA website for all equity securities (listed and unlisted).  FINRA also is considering potential short interest position reporting and dissemination enhancements to improve the usefulness of short interest data to FINRA, other regulators, investors, and other market participants by collecting more timely and granular information on short interest positions.  In addition to the specific questions noted below, FINRA requests comment on all aspects of this Notice, including the costs and burdens associated with these potential enhancements.  FINRA requests that commenters provide empirical data or other factual support for their comments wherever possible. 

Exchange-listed Equity Securities

As discussed above, FINRA currently disseminates on the FINRA website short interest position information for OTC equity securities. For exchange-listed securities, FINRA provides reported short interest position information to the applicable listing exchange for processing and publication, and each listing exchange determines the timing and content of its disseminated short interest data. FINRA is considering consolidating the publication of short interest data on the FINRA website for both listed and unlisted securities. 

  • FINRA requests comment on whether FINRA should publish on the FINRA website short interest data for all equity securities (listed and unlisted).
  • 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.
  • Are there any aspects of the proposal that should apply differently to exchange-listed equity securities or OTC equity securities? If so, please explain.
  • Would the enhancements discussed herein be beneficial to investors and the marketplace even if the changes to dissemination were implemented only with respect to OTC equity securities? 
  • Are there any expected potential competitive effects associated with this change?

Content of Short Interest Data

FINRA is considering changes to the content of the information firms are required to report as well as to the fields published by FINRA in disseminated short interest data. 

Proprietary and Customer Account Categorization

As discussed above, FINRA is considering requiring firms to specify the portion of the total short position that is held across proprietary accounts and the portion that is held across customer accounts. 

  • Do firms anticipate any operational challenges with separately reporting the portion of short interest positions held across customer accounts and proprietary accounts?
  • What updates or changes to systems would be necessary to facilitate this change? 
  • FINRA believes this level of account type information would be useful to FINRA in performing its regulatory functions and is interested in obtaining feedback on whether investors and other market participants also would find this additional information useful (e.g., to assess investor sentiment about a stock). Therefore, FINRA requests comment on whether publicly providing the portion of the total short position that is held across customer accounts and the portion that is held across proprietary accounts (aggregated per symbol across all firms) in disseminated short interest data would be beneficial. 
  • Might making this information publicly available lead to any negative outcomes regarding how short interest position information is interpreted, the willingness of market participants to take short positions or otherwise?
  • Should FINRA consider requiring an even more granular breakdown of positions, e.g., should FINRA require firms to further separate the positions into retail and institutional investor categories? With respect to positions held in proprietary accounts, should FINRA require firms to further separate the positions into market maker and non-market maker categories? If so, should this further granularity also be provided in publicly disseminated short interest data (aggregated per symbol across all firms)?
  • Would information on the portion of total short interest that is fully or partially hedged be useful to market participants? Is this information also ascertainable by members with respect to customer short positions? What factors would impact a member’s ability to determine with certainty whether a short position is fully or partially hedged and report this information to FINRA?
  • Would information on the portion of total short interest that is fully or partially hedged be useful to market participants even if incomplete, for example, if it was only available for proprietary short positions or otherwise did not reflect all hedging activity?
  • Do commenters believe that short interest in proprietary positions are likely to be as meaningful as short interest in customer positions? What are commenters’ views on whether proprietary or customer short interest is more likely to reflect negative sentiment. Is one more likely to be short-term? Is one more likely to be hedged?
  • What, if any, additional costs would commenters anticipate if FINRA were to require firms to report the portion of short interest positions held across customer accounts and the portion of short interest positions held across proprietary accounts?
  • What implementation period would be appropriate to provide members with sufficient time to make the systems changes necessary to comply with these changes?
  • Are there any expected potential competitive effects associated with this change, whether across member firms or between member firms and non-member firms?

Account-level Position Information

As discussed above, as an alternative to proprietary and customer account categorization, FINRA is considering requiring firms to report to FINRA (for regulatory purposes only; not to be disseminated publicly) short interest position information at the account level.21 

  • Do firms anticipate any operational challenges with reporting short interest position information to FINRA on an account-level basis?
  • FINRA also is considering a means of consistently identifying account holders across reporting firms. What do commenters think would be the most appropriate means for consistently identifying individual account holders across firms for purposes for this proposal? 
  • What updates or changes to systems would be necessary to facilitate this change? 
  • If FINRA were to adopt this change, would it be more appropriate to limit the account-level reporting requirement to accounts where a beneficial owner’s reportable short interest in a security (aggregated across all of such customer’s accounts at the firm) is 3 percent or more of the TSO? Is 3 percent the appropriate TSO threshold? Please discuss.
  • What, if any, additional costs would commenters anticipate if FINRA were to require firms to report short interest position information to FINRA on an account-level basis?
  • What implementation period would be appropriate to provide members with sufficient time to make the systems changes necessary to comply with this requirement?

Synthetic Short Positions

FINRA is considering requiring firms to reflect synthetic short positions in their short interest reports. 

  • FINRA proposes to require that firms include synthetic short positions, such as the sale of a call option and purchase of a put option (where the options have the same strike price and expiration month), in short interest reports. FINRA requests comment on whether there are any other types of strategies (involving options, swaps or other products) that firms should be required to report as synthetic short interest. Please explain.
  • FINRA requests comment on the feasibility of reporting synthetic short interest.
  • What updates or changes to systems would be necessary to facilitate reporting of synthetic short interest? 
  • FINRA requests comment on whether synthetic short interest should be identified in disseminated short interest data (aggregated per symbol across all firms) in addition to being available for regulatory purposes. Why or why not?
  • What, if any, additional costs would commenters anticipate if FINRA were to require firms to report synthetic short interest?
  • What implementation period would be appropriate to provide members with sufficient time to make the systems changes necessary to comply with this requirement?
  • Are there any expected potential competitive effects associated with this change, whether across member firms or between member firms and non-member firms?

TSO and Public Float

FINRA is considering including in FINRA-disseminated short interest data, where available, a security’s TSO and public float. FINRA would obtain the TSO and public float information from a third-party source; therefore, this change would not alter firms’ reporting requirements. 

  • Do commenters agree that including TSO and public float information in disseminated short interest data would be useful to investors and other market participants? Why or why not?
  • TSO and public float information may not be readily available for all OTC equity securities. Do commenters believe that providing this information in some cases but not others would cause confusion or present any other problems for users of the data?
  • Are there any expected potential competitive effects associated with this change, whether across member firms or between member firms and non-member firms?

Threshold List Field

As discussed above, FINRA is considering including in disseminated short interest data a new field that would indicate if the security is a threshold security. This change would not alter firms’ reporting requirements. 

  • Do commenters agree that identifying threshold securities in disseminated short interest would be useful to investors and other market participants? Why or why not?

Loan Obligations Resulting From Arranged Financing

As discussed above, FINRA is considering requiring members who offer arranged financing programs to report outstanding stock borrows by customers in those programs as short interest. 

  • FINRA requests comment on whether firms currently offer this type of arranged financing service to customers. Where offered, FINRA requests feedback on whether the shares are loaned to the customer by an affiliate of the member and, if so, whether such affiliate is domestic or foreign. FINRA also requests comment on whether any firms have programs where they arrange for customers to close out short positions by borrowing shares from unaffiliated lenders.
  • FINRA requests comment on whether outstanding stock borrows by customers in arranged financing programs should be reflected in short interest reports. Should all outstanding stock borrows (including outside of an arranged financing program) be reportable to FINRA along with total short interest?
  • FINRA requests comment on the feasibility of reflecting outstanding stock borrows by customers in arranged financing programs in short interest reports. 
  • What updates or changes to systems would be necessary to facilitate this change? 
  • What, if any, additional costs would commenters anticipate if FINRA were to require firms to reflect outstanding stock borrows by customers in arranged financing programs in short interest reports?
  • What implementation period would be appropriate to provide members with sufficient time to make the systems changes necessary to comply with this requirement?
  • Are there any expected potential competitive effects associated with this change, whether across member firms or between member firms and non-member firms?

Frequency and Timing of Short Interest Position Reporting and Data Dissemination

As discussed above, FINRA is considering changes that would provide FINRA, other regulators, investors, and other market participants with more timely access to short interest data.  Specifically, FINRA is considering reducing firm reporting and processing times from the current twice a month and two-day timeframes, respectively.  

  • FINRA is considering whether daily or weekly short interest position reporting would be preferable. What are commenters’ views on the preferred frequency of short interest position reporting?
  • FINRA requests that firms provide detailed information regarding the feasibility of reporting short interest information to FINRA on a daily versus weekly basis. 
  • What updates or changes to firms’ systems would be necessary to facilitate a change to daily reporting? What updates would be necessary to facilitate a change to weekly reporting?
  • What challenges do firms anticipate with complying with a daily reporting timeframe? What challenges do firms anticipate with complying with a weekly reporting timeframe? 
  • What, if any, additional costs would commenters anticipate if FINRA reduced the short interest reporting frequency to daily submissions? What, if any, additional costs would commenters anticipate if FINRA reduced the short interest reporting frequency to weekly submissions?  
  • Do commenters believe that daily submissions, combined with a one-day reduction in firm turnaround time and a one-day reduction in FINRA processing time would be beneficial in providing more timely transparency regarding short interest position information? Why or why not?
  • Do commenters believe that weekly submissions, combined with a one-day reduction in firm turnaround time and a one-day reduction in FINRA processing time would be beneficial in providing more timely transparency regarding short interest? Why or why not?
  • What challenges do firms anticipate with complying with a one-day reporting turnaround time? For example, would one day provide sufficient time to validate the accuracy of the short interest information prior to reporting to FINRA?
  • What, if any, additional costs would commenters anticipate if FINRA were to require firms to reduce the reporting turnaround time to one day?
  • Would a one-day reduction in both firm and FINRA turnaround times be beneficial (i.e., short interest information would be disseminated two days earlier), even with the current twice a month reporting schedule? 
  • What implementation period would be appropriate to provide members with sufficient time to make the modifications necessary to comply with the potential changes described above?
  • To what negative outcomes, if any, may higher frequency short interest disclosures lead? 
  • Are there any expected potential competitive effects associated with this change, whether across member firms or between member firms and non-member firms?

Information on Allocations of Fail-To-Deliver Positions  

FINRA also requests comment on a potential new rule to require that participants of a registered clearing agency submit a report to FINRA (for regulatory purposes only; not for public dissemination) of daily allocations to correspondent firms of fail-to-deliver positions pursuant to Rule 204(d) of Regulation SHO. 

  • FINRA envisions that allocation information would be organized in daily files, but requests comment on the feasibility of reporting this information to FINRA on a daily versus weekly basis. If daily, how many days after the applicable allocation date would be necessary to process and report the information to FINRA (e.g., close of business on allocation date +1, allocation date +2)? If weekly, how many days after the close of the reporting period would be necessary to process and report the information to FINRA?
  • Do firms anticipate any operational challenges with reporting to FINRA the daily allocations to correspondent firms of Rule 204(d) fail-to-deliver positions?
  • Is the fail-to-deliver allocation information that would be covered by this requirement currently kept in a form that could readily be compiled for reporting?
  • What updates or changes to systems would be necessary to facilitate this change? 
  • What, if any, additional costs would commenters anticipate if FINRA were to require participants of a registered clearing agency to report to FINRA the daily allocations to correspondent firms of Rule 204(d) fail-to-deliver positions?
  • What implementation period would be appropriate to provide firms with sufficient time to make the systems changes necessary to comply with this requirement?
  • Are there any expected potential competitive effects associated with this change, whether across member firms or between member firms and non-member firms?

FINRA plans to use the additional data proposed to be collected for its short sale regulatory program of both OTC equity and exchange-listed securities. FINRA requests feedback on any potential unintended consequences of the proposed changes. 

Other Short Sale-Related Initiatives

  • Do commenters believe that FINRA should explore creating a reporting framework around stock lending activity? For example, member firms that engage in stock lending transactions could be required to report loan terms to FINRA—e.g., rebate rate (for new loans, open daily loans and re-rates), loan amount, contra-party information. After experience is gained with the reporting regime and resulting data, FINRA could consider the appropriateness of a phased approach to providing public transparency into stock loan rebate rates and other negotiated terms.
  • Are there any other short sale-related changes not discussed above that commenters recommend? Please explain.   

Endnotes


1 Parties should submit in their comments only personally identifiable information, such as phone numbers and addresses, that they wish to make available publicly. FINRA, however, reserves the right to redact, remove or decline to post comments that are inappropriate for publication, such as vulgar, abusive or potentially fraudulent comment letters. FINRA also reserves the right to redact or edit personally identifiable information from comment submissions.

2 See SEA Section 19 and rules thereunder. After a proposed rule change is filed with the SEC, the proposed rule change generally is published for public comment in the Federal Register. Certain limited types of proposed rule changes take effect upon filing with the SEC. See SEA Section 19(b)(3) and SEA Rule 19b-4.

3 See 17 CFR 242.200-204.

4 See FINRA Rule 4560; see also Regulatory Notice 12-38 (August 2012). Rule 4560 requires firms to record and report all gross short positions existing in each individual firm or customer account, including the account of a broker-dealer, that resulted from either a “short sale,” as that term is defined in Rule 200(a) of SEC Regulation SHO, or where the transaction(s) that caused the short position was marked “long,” consistent with Regulation SHO, due to the firm’s or the customer’s net long position at the time of the transaction. Firms must report only those short positions resulting from short sales that have settled or reached settlement date by the close of the reporting settlement date designated by FINRA.

5 The “days to cover” field is a FINRA-calculated number representing the number of days of average share volume it would require to cover the current short interest position.

6 In addition to short interest reporting under Rule 4560, FINRA’s equity trade reporting rules require members to identify short sales when reporting transactions to FINRA equity trade reporting facilities. FINRA uses this information to derive short sale volume data and make it publicly available. Short sale volume data differs from short interest data. Published short interest data reflects short positions held across all firms at a specific moment in time on two discrete days each month and is derived from short interest information reported to FINRA pursuant to Rule 4560. In contrast, the short sale files FINRA publishes are derived from transactions that are reported to FINRA’s equity trade reporting facilities. There are two types of short sale volume files: (1) the daily short sale volume files, which provide aggregated volume by security for all short sales executed and reported to a FINRA Trade Reporting Facility (TRF), the Alternative Display Facility (ADF), or the OTC Reporting Facility (ORF) during normal market hours; and (2) the monthly short sale transaction files, which provide detailed trade activity of all short sale trades executed and reported to the ADF or a TRF during normal market hours, as well as after-hours. The short sale files include only trades reported for public dissemination purposes. See e.g., FINRA Rules 6182 (Trade Reporting of Short Sales) and 6624 (Trade Reporting of Short Sales). See also Information Notice 5/10/19 (Understanding Short Sale Volume Data on FINRA’s Website). 

7 While FINRA Rule 4560 applies to the activity of all FINRA members, including those that also are members of a national securities exchange, FINRA notes that each national securities exchange determines for its listed securities the appropriate content of published short interest data. In addition, the national securities exchanges’ short interest reporting rules would govern the conduct of exchange-only members. See e.g., NYSE Rule 4560 and Nasdaq Equity 9 Business Conduct, Section 9.

8 See Regulatory Notice 08-13 (March 2008). 

9 See supra note 5.

10 The “revision flag” indicates that the previous short interest position in the security was revised since the prior reporting cycle.

11 Even if FINRA does not consolidate publication of short interest data in all equity securities on the FINRA website, the reporting changes discussed in this section would be applicable to firms’ short interest reporting for both exchange-listed and OTC equity securities.

12 The proposed threshold security field would indicate whether a security is a “threshold security,” as defined by Rule 203 of SEC Regulation SHO or a “non-reporting threshold security,” as defined by FINRA Rule 4320. Rule 203(c)(6) of Regulation SHO generally defines a “threshold security” as any equity security of an issuer that is registered under Section 12, or that is required to file reports pursuant to Section 15(d), of the Exchange Act: where for five consecutive settlement days there is an aggregate fail-to-deliver position at a registered clearing agency of 10,000 shares or more and that is equal to at least 0.5 percent of the issuer’s TSO; and the security is included on a list published by a self-regulatory organization. FINRA Rule 4320 generally defines a “non-reporting threshold security,” as any equity security of an issuer that is not registered pursuant to Section 12 of the Exchange Act and for which the issuer is not required to file reports pursuant to Section 15(d) of the Exchange Act: where for five consecutive settlement days there is an aggregate fail-to-deliver position at a registered clearing agency of 10,000 shares or more and for which on each settlement day during the five consecutive settlement day period, the reported last sale during normal market hours for the security on that settlement day would value the aggregate fail-to-deliver position at $50,000 or more; and the security is included on a list published by FINRA.

13 FINRA also is considering whether it is desirable to reduce firm turnaround time to no later than one business day after the reporting settlement date (i.e., by 6:00 p.m. ET on the business day after the designated reporting settlement date) even if the current twice a month reporting cycle is retained. 

14 SEC staff guidance states that: 

“Rule 204(d) permits the participant to reasonably allocate a portion of a fail-to-deliver position to another registered broker or dealer for which it clears trades or for which it is responsible for settlement, based on such broker’s or dealer’s short position. If the participant has reasonably allocated the fail-to-deliver position, the provisions of Rule 204 relating to such fail-to-deliver position, including the pre-borrow requirement, apply to such registered broker or dealer that was allocated the fail-to-deliver position, and not to the participant.” See Division of Market Regulation: Responses to Frequently asked Questions Concerning Regulation SHO, # 5.4 (October 15, 2015).

15 This calculation excludes OTC equity securities for which there was no volume reported in the security over the period.

16 This calculation excludes exchange-listed equity securities for which there was no volume reported in the security over the period.

17 Truong X. Duong, Zsuzsa R. Huszar & Takeshi Yamada, The Costs and Benefits of Short Sale Disclosure, 53 Journal of Banking and Finance 124-130 (2015).

Charles M. Jones, Adam V. Reed & William Waller, Revealing Shorts: An Examination of Large Short Position Disclosures, 29(12) The Review of Financial Studies 3278-3320 (2016).

Duong et al. study a change in Japan requiring traders to report short positions in excess of 0.25 percent of shares outstanding to exchanges within 24 hours, which are then reported to the public within another 24 hours. Jones et al. study a similar change in the European Union where any short position exceeding 0.5 percent of shares outstanding must publicly disclose the position by the next business day. Both studies find the requirements reduced short selling.

18 Don M. Autore, Thomas J. Boulton & Marcus V. Braga-Alves, Failures to Deliver, Short Sales Constraints, and Stock Overvaluation, 50(2) Financial Review 143-172 (2015).

19 Carole Comerton-Forde, Binh H. Do, Philip Gray & Tom Manton, Assessing the Information Content of Short-Selling Metrics Using Daily Disclosures, 64 Journal of Banking and Finance188-204 (2016).

20 See supra note 18.

21 FINRA collects short interest reports through FINRA Gateway. The data collected from firms through short interest reporting is distinct from, and cannot be derived from, the information available through the Consolidated Audit Trail (CAT). While members are required to report the material terms of an order to CAT (for sell orders, members are required to report whether the order is long, short or short exempt), this information currently cannot be used to create a snapshot of gross short positions existing in each account at a particular point in time.

The views, expressions, findings and opinions expressed in the comments on this Web page are solely those of the author(s) and FINRA accepts no responsibility for the content of the comments:
Date Commenter
Phillip Worts Comment On Regulatory Notice 21-19
Anonymous-N Comment On Regulatory Notice 21-19
Jennifer Smith Comment On Regulatory Notice 21-19
Samuel Bendorff Comment On Regulatory Notice 21-19
Paul Comment On Regulatory Notice 21-19
Stephen Conover Comment On Regulatory Notice 21-19
Anonymous-TO Comment On Regulatory Notice 21-19
Ryan Reynolds Comment On Regulatory Notice 21-19
Alec Pom Comment On Regulatory Notice 21-19
Nils Brikers Comment On Regulatory Notice 21-19
Brock Butterfield Comment On Regulatory Notice 21-19
ElRojos Comment On Regulatory Notice 21-19
Brian Jensen Comment On Regulatory Notice 21-19
Mark C Gallupe Comment On Regulatory Notice 21-19
Ryan Bollinger Comment On Regulatory Notice 21-19
Steve Selak Comment On Regulatory Notice 21-19
Marc Dostie Comment On Regulatory Notice 21-19
Michael Butler Comment On Regulatory Notice 21-19
Luke Witte Comment On Regulatory Notice 21-19
Mike Comment On Regulatory Notice 21-19
Christopher Sorensen Comment On Regulatory Notice 21-19
Anonymous-B Comment On Regulatory Notice 21-19
Justin Duty Comment On Regulatory Notice 21-19
Leonidas Georgiou Comment On Regulatory Notice 21-19
Troy Stark Comment On Regulatory Notice 21-19
Laura Ritter Comment On Regulatory Notice 21-19
Aaron Comment On Regulatory Notice 21-19
Mike Soltys Comment On Regulatory Notice 21-19
Sean B Comment On Regulatory Notice 21-19
Chris Contay Comment On Regulatory Notice 21-19
Jeremy Hohengarten Comment On Regulatory Notice 21-19
Anonymous-BH Comment On Regulatory Notice 21-19
Nicolas Bean Comment On Regulatory Notice 21-19
Brandon Smith Comment on Regulatory Notice 21-19
Joe Comment On Regulatory Notice 21-19
Ioren Ipsum Comment On Regulatory Notice 21-19
Nicolas Benham Comment On Regulatory Notice 21-19
Stephanie Comment On Regulatory Notice 21-19
Chris Martinez Comment On Regulatory Notice 21-19
Lana Mosley Comment On Regulatory Notice 21-19
Anonymous-RB Comment On Regulatory Notice 21-19
Matt Gilley Comment On Regulatory Notice 21-19
Robert Andersen Comment On Regulatory Notice 21-19
Bruce Szczechowski Comment On Regulatory Notice 21-19
Anthony Lathiago Comment On Regulatory Notice 21-19
Amy W Comment On Regulatory Notice 21-19
Joe Itoh Comment On Regulatory Notice 21-19
Kyle Winters Comment On Regulatory Notice 21-19
Todd Hill Comment On Regulatory Notice 21-19
Lindsay Meeks Comment On Regulatory Notice 21-19
Kevin Moran Comment On Regulatory Notice 21-19
Zero Cycles Comment On Regulatory Notice 21-19
JD Cumpson Comment On Regulatory Notice 21-19
Jesse Welter Comment On Regulatory Notice 21-19
Charlie Kim Comment on Regulatory Notice 21-19
Jonathan Comment On Regulatory Notice 21-19
The Delo Comment On Regulatory Notice 21-19
Mason Welp Comment On Regulatory Notice 21-19
Chad Thomas Comment On Regulatory Notice 21-19
Anonymous-ED Comment On Regulatory Notice 21-19
Eugene Lau Comment On Regulatory Notice 21-19
Daniel Cave Comment On Regulatory Notice 21-19
Chris Tate Comment On Regulatory Notice 21-19
Dave Mortimer Comment On Regulatory Notice 21-19
Michael E Comment On Regulatory Notice 21-19
Ryan Calarese Comment On Regulatory Notice 21-19
Kimberly Baillieul Comment On Regulatory Notice 21-19
Anonymous-TF Comment On Regulatory Notice 21-19
Matt Comment On Regulatory Notice 21-19
Josh Blanchard Comment On Regulatory Notice 21-19
Shannon Pender Comment On Regulatory Notice 21-19
Jennifer Lawson Comment On Regulatory Notice 21-19
Beth Joy Comment On Regulatory Notice 21-19
Andrew Comment On Regulatory Notice 21-19
Shawn Dutill Comment On Regulatory Notice 21-19
Ashton Parker Comment On Regulatory Notice 21-19
Dr. Matthew R. White Comment On Regulatory Notice 21-19
William Boyajian Comment On Regulatory Notice 21-19
Dionte Pounds Comment On Regulatory Notice 21-19
Brian Willis Comment On Regulatory Notice 21-19
Constantin Hennrich Comment On Regulatory Notice 21-19
Fred Whet Comment On Regulatory Notice 21-19
Luuk Blum Comment On Regulatory Notice 21-19
Todd Felte Comment On Regulatory Notice 21-19
Mark Williams Comment On Regulatory Notice 21-19
Adam Newton Comment On Regulatory Notice 21-19
Ricky Syad Comment On Regulatory Notice 21-19
P Deneka Comment On Regulatory Notice 21-19
Shannon MacTurk Comment On Regulatory Notice 21-19
Kyle Aken Comment On Regulatory Notice 21-19
Michael Brady Comment On Regulatory Notice 21-19
Faith Brandt Comment On Regulatory Notice 21-19
Ron Velotta Comment On Regulatory Notice 21-19
Jonathon Sonnenberg Comment On Regulatory Notice 21-19
Alana furlow Comment On Regulatory Notice 21-19
Anonymous-RP Comment On Regulatory Notice 21-19
Denis Comment On Regulatory Notice 21-19
Anonymous-PB Comment On Regulatory Notice 21-19
Steven Thiakos Comment On Regulatory Notice 21-19
Retail Shareholder Comment On Regulatory Notice 21-19
Jackson Hosler Comment On Regulatory Notice 21-19
Sean L. Bollinger Comment On Regulatory Notice 21-19
L D Comment On Regulatory Notice 21-19
William Lehnert Comment On Regulatory Notice 21-19
Anonymous-CH Comment On Regulatory Notice 21-19
Ilya Comment On Regulatory Notice 21-19
Dave Comment On Regulatory Notice 21-19
James Walker Comment On Regulatory Notice 21-19
Manny Harris Comment On Regulatory Notice 21-19
Anthony Mazzola Comment On Regulatory Notice 21-19
Sam Floyd Comment On Regulatory Notice 21-19
Anonymous-CN Comment On Regulatory Notice 21-19
Bridget Comment On Regulatory Notice 21-19
Benjamin Kravitz Comment On Regulatory Notice 21-19
Omar Andrade Comment On Regulatory Notice 21-19
Evan Picow Comment On Regulatory Notice 21-19
Jackson Black Comment On Regulatory Notice 21-19
Dan Ganancial Comment On Regulatory Notice 21-19
Craig Bruenderman Comment On Regulatory Notice 21-19
Anonymous-PW Comment On Regulatory Notice 21-19
Jon Comment On Regulatory Notice 21-19
Zach Davis Comment On Regulatory Notice 21-19
Antonio Comment On Regulatory Notice 21-19
Andrew Warren Comment On Regulatory Notice 21-19
Nikki Albert Comment On Regulatory Notice 21-19
Joel Williams Comment On Regulatory Notice 21-19
Casey Pavich Comment On Regulatory Notice 21-19
Matthew Pauling Comment On Regulatory Notice 21-19
Daniel Skrzypek Comment On Regulatory Notice 21-19
Mike Comment On Regulatory Notice 21-19
Nick Dicamillo Comment On Regulatory Notice 21-19
Kyle M Comment On Regulatory Notice 21-19
Scott Townend Comment On Regulatory Notice 21-19
Anonymous-A Comment On Regulatory Notice 21-19
Anonymous-SC Comment On Regulatory Notice 21-19
Tanner Comment On Regulatory Notice 21-19
Michael Parker Comment On Regulatory Notice 21-19
Glen Michael Miller Comment On Regulatory Notice 21-19
Evan Comment On Regulatory Notice 21-19
Jonathan S Comment On Regulatory Notice 21-19
Cody Daluz Comment On Regulatory Notice 21-19
Marcelo Comment On Regulatory Notice 21-19
Paul Nguyen Comment On Regulatory Notice 21-19
Anonymous-ET Comment On Regulatory Notice 21-19
Mark Hemsworth Comment On Regulatory Notice 21-19
Anonymous-TK Comment On Regulatory Notice 21-19
Amber Comment On Regulatory Notice 21-19
Chris Marsh Comment On Regulatory Notice 21-19
Chris Cunningham Comment On Regulatory Notice 21-19
Timothy Comment On Regulatory Notice 21-19
Farrah Moore Comment On Regulatory Notice 21-19
Anonymous-SS Comment On Regulatory Notice 21-19
Ryan Hesse Comment On Regulatory Notice 21-19
Anonymous-TB Comment On Regulatory Notice 21-19
Michael R Demirjian Comment On Regulatory Notice 21-19
Chris Crawford Comment On Regulatory Notice 21-19
Brenden Gravois Comment On Regulatory Notice 21-19
Anthony George Comment On Regulatory Notice 21-19
Phillip Moore Comment On Regulatory Notice 21-19
Daniel Dickson Comment On Regulatory Notice 21-19
Edward M Ryan Comment On Regulatory Notice 21-19
Anthony Rivas Comment On Regulatory Notice 21-19
Tucker Aiton Comment On Regulatory Notice 21-19
Connie Rodriguez Comment On Regulatory Notice 21-19
Scott Olsen Comment On Regulatory Notice 21-19
Ashley G. Comment On Regulatory Notice 21-19
Ryan McCabe Comment On Regulatory Notice 21-19
Sarah Comment On Regulatory Notice 21-19
Margaret McElveen Comment On Regulatory Notice 21-19
Jagroop Singh Comment On Regulatory Notice 21-19
Chris Comment On Regulatory Notice 21-19
Nicholas Morvan Comment On Regulatory Notice 21-19
Gregory Dusch Comment On Regulatory Notice 21-19
Moua Yang Comment On Regulatory Notice 21-19
Chris Comment On Regulatory Notice 21-19
Josh Parker Comment On Regulatory Notice 21-19
Nichole Springer Comment On Regulatory Notice 21-19
Garrett McMahan Comment On Regulatory Notice 21-19
Jeff Swan Comment On Regulatory Notice 21-19
Pierre Addo Comment On Regulatory Notice 21-19
Eric Comment On Regulatory Notice 21-19
Glenda Jovel Comment On Regulatory Notice 21-19
Vincent Timpano Comment On Regulatory Notice 21-19
Buddy Morsello Comment On Regulatory Notice 21-19
Chelsie Comment On Regulatory Notice 21-19
Jimmy Jones Comment On Regulatory Notice 21-19
Sandy Wright Comment On Regulatory Notice 21-19
Terry Montgomery Comment On Regulatory Notice 21-19
Phillip Moore Comment On Regulatory Notice 21-19
Bart Kincaid Comment On Regulatory Notice 21-19
Phil Comment On Regulatory Notice 21-19
Samuel Museus Comment On Regulatory Notice 21-19
Sariena Carmichael Comment On Regulatory Notice 21-19
Ryan O'Connor Comment On Regulatory Notice 21-19
Rachael Barr Comment On Regulatory Notice 21-19
Jonathan Maxwell Comment On Regulatory Notice 21-19
Jon Chastain Comment On Regulatory Notice 21-19
Chase Maglangit Comment On Regulatory Notice 21-19
Anonymous-CF Comment On Regulatory Notice 21-19
Landry Haynes Comment On Regulatory Notice 21-19
Ryan Iseneker Comment On Regulatory Notice 21-19
Ryan King Comment On Regulatory Notice 21-19
Nicholas James Martinico Comment On Regulatory Notice 21-19
Jay Pent Comment On Regulatory Notice 21-19
Franklin Murton Comment On Regulatory Notice 21-19
Jamie Ryan Davis Comment On Regulatory Notice 21-19
Jorge Goias Comment On Regulatory Notice 21-19
Allie Comment On Regulatory Notice 21-19
Jared Brito Comment On Regulatory Notice 21-19
Carl Davis Comment On Regulatory Notice 21-19
Anonymous-BJ Comment On Regulatory Notice 21-19
Anonymous-MK Comment On Regulatory Notice 21-19
Michael Perez Comment On Regulatory Notice 21-19
Matthew Khomsi Comment On Regulatory Notice 21-19
Wes Guild Comment On Regulatory Notice 21-19
Matt Kneram Comment On Regulatory Notice 21-19
Arthur Henderson Comment On Regulatory Notice 21-19
Josh Owens Comment On Regulatory Notice 21-19
Ariel Zimmer Comment On Regulatory Notice 21-19
Jonathan Martel Comment On Regulatory Notice 21-19
Twitch Comment On Regulatory Notice 21-19
Anonymous-SM Comment On Regulatory Notice 21-19
Bohdan Zavalishyn Comment On Regulatory Notice 21-19
Robert Luna Comment On Regulatory Notice 21-19
David Fay Comment On Regulatory Notice 21-19
Shane Heule Comment On Regulatory Notice 21-19
Stevie Y Comment On Regulatory Notice 21-19
Anonymous-CC Comment On Regulatory Notice 21-19
Kevin Burge Comment On Regulatory Notice 21-19
Patrick Carey Comment On Regulatory Notice 21-19
Anonymous-BG Comment On Regulatory Notice 21-19
Jonathan Martin Comment On Regulatory Notice 21-19
Stefan Flores Comment On Regulatory Notice 21-19
Vishal Khana Comment On Regulatory Notice 21-19
Brandon S Fountain Comment On Regulatory Notice 21-19
Malcolm Tosh Comment On Regulatory Notice 21-19
Ali Comment On Regulatory Notice 21-19
John Davis Comment On Regulatory Notice 21-19
Luis Munet Comment On Regulatory Notice 21-19
Mark Williams Comment On Regulatory Notice 21-19
Brandon Button Comment On Regulatory Notice 21-19
Silva Badalian Comment On Regulatory Notice 21-19
Keith Brumitt Comment On Regulatory Notice 21-19
Forrest Comment On Regulatory Notice 21-19
Lucy Hamer Comment On Regulatory Notice 21-19
Zaeem Hadi Comment On Regulatory Notice 21-19
Kevin Pinkerton Comment On Regulatory Notice 21-19
Matt Dossantos Comment On Regulatory Notice 21-19
Eric Comment On Regulatory Notice 21-19
Sean Hartig Comment On Regulatory Notice 21-19
Shaun Safford Comment On Regulatory Notice 21-19
Anonymous-KM Comment On Regulatory Notice 21-19
Michael Conway Comment On Regulatory Notice 21-19
James Mayse Comment On Regulatory Notice 21-19
Anonymous-KW Comment On Regulatory Notice 21-19
Andy Taylor Comment On Regulatory Notice 21-19
Benjamin Capello Comment On Regulatory Notice 21-19
Brittney Johnson Comment On Regulatory Notice 21-19
Al Pom Comment On Regulatory Notice 21-19
Gavin Hewlett Comment On Regulatory Notice 21-19
Jaryn Sabey Comment On Regulatory Notice 21-19
Garrett Voss Comment On Regulatory Notice 21-19
Anonymous-Z Comment On Regulatory Notice 21-19
Robert M Feidler Comment On Regulatory Notice 21-19
Felipe Lavoy Comment On Regulatory Notice 21-19
Michael Welch Comment On Regulatory Notice 21-19
Marlon Rivera Comment On Regulatory Notice 21-19
Dustin Hammond Comment On Regulatory Notice 21-19
Anon Comment On Regulatory Notice 21-19
Chad W Comment On Regulatory Notice 21-19
Srendius Comment On Regulatory Notice 21-19
Chinelo Steiner Comment On Regulatory Notice 21-19
Anonymous-JE Comment On Regulatory Notice 21-19
Barry Greer Comment On Regulatory Notice 21-19
Angela Heath Comment On Regulatory Notice 21-19
Tara Hunt Comment On Regulatory Notice 21-19
Colby Rosado Comment On Regulatory Notice 21-19
Jared Aleman Comment On Regulatory Notice 21-19
Dustin Comment On Regulatory Notice 21-19
Matthew Richardson Comment On Regulatory Notice 21-19
Brandon Bryant Comment On Regulatory Notice 21-19
Benjamin Duckles Comment On Regulatory Notice 21-19
Hunter Comment On Regulatory Notice 21-19
Scott Lieberman Comment On Regulatory Notice 21-19
Mouktar Albert Comment On Regulatory Notice 21-19
Carson Stilp Comment On Regulatory Notice 21-19
Ngawang Gyaltso Comment On Regulatory Notice 21-19
Mario Cobian Comment On Regulatory Notice 21-19
Susan Galati Comment On Regulatory Notice 21-19
David Jason Eversole Comment On Regulatory Notice 21-19
Bob Harward Comment On Regulatory Notice 21-19
Gary John Drudge-Coates Comment On Regulatory Notice 21-19
Chris Shu Comment On Regulatory Notice 21-19
Jennifer Lynn Hudgens Comment On Regulatory Notice 21-19
Sandy Leff Comment On Regulatory Notice 21-19
Chad Osborne Comment On Regulatory Notice 21-19
Derek Fowler Comment On Regulatory Notice 21-19
Chuck Ryan Comment On Regulatory Notice 21-19
Karol Gliniewicz Comment On Regulatory Notice 21-19
Sead Hajzeri Comment On Regulatory Notice 21-19
Anonymous-JT Comment On Regulatory Notice 21-19
Gabriel Comment On Regulatory Notice 21-19
Eren Comment On Regulatory Notice 21-19
Chris Dasconio Comment On Regulatory Notice 21-19
Jonathan Epifano Comment On Regulatory Notice 21-19
Jared Lehmann Comment On Regulatory Notice 21-19
Hunter A Robinson Comment On Regulatory Notice 21-19
John Comment On Regulatory Notice 21-19
John Decrescentis Comment On Regulatory Notice 21-19
Ben Lynch Comment On Regulatory Notice 21-19
Brian Doherty Comment On Regulatory Notice 21-19
Julius Kelly Comment On Regulatory Notice 21-19
Jerry Logan Comment On Regulatory Notice 21-19
Trong Vuong Comment On Regulatory Notice 21-19
Braylan Dunn Comment On Regulatory Notice 21-19
Juan Chavez Comment On Regulatory Notice 21-19
Marc Green Comment On Regulatory Notice 21-19
David Comment On Regulatory Notice 21-19
Amit Comment On Regulatory Notice 21-19
Luis Madrid Comment On Regulatory Notice 21-19
David Comment On Regulatory Notice 21-19
Dina Riggs Comment On Regulatory Notice 21-19
Nicolas Christman Comment On Regulatory Notice 21-19
Prabhjinder Singh Dosanjh Comment On Regulatory Notice 21-19
Justin Paglia Comment On Regulatory Notice 21-19
Matt Comment On Regulatory Notice 21-19
Paul Comment On Regulatory Notice 21-19
Jeffrey Krumm Comment On Regulatory Notice 21-19
Roland Lischalk Comment On Regulatory Notice 21-19
Anonymous-NJ Comment On Regulatory Notice 21-19
Colton Young Comment On Regulatory Notice 21-19
Doug Ochsner Comment On Regulatory Notice 21-19
Jameel Branch Comment On Regulatory Notice 21-19
Melissa Shapiro Comment On Regulatory Notice 21-19
Justin Acosta Comment On Regulatory Notice 21-19
Ricky Nicholas D'Anna Comment On Regulatory Notice 21-19
Juan Agosto Comment On Regulatory Notice 21-19
Manuel Aragonez Comment On Regulatory Notice 21-19
Al Todd Comment On Regulatory Notice 21-19
Hassan Beydoun Comment On Regulatory Notice 21-19
Derek Smith Comment On Regulatory Notice 21-19
Jared Comment On Regulatory Notice 21-19
Victor Chaney Comment On Regulatory Notice 21-19
Josh Thomas Comment On Regulatory Notice 21-19
Trevor Knowles Comment On Regulatory Notice 21-19
Gil Garay Comment On Regulatory Notice 21-19
Alex Schmitt Comment On Regulatory Notice 21-19
Anonymous-EW Comment On Regulatory Notice 21-19
Tracey Heasley Comment On Regulatory Notice 21-19
Shane Grillo Comment On Regulatory Notice 21-19
Anonymous-RI Comment On Regulatory Notice 21-19
Moe A Comment On Regulatory Notice 21-19
Anonymous-DL Comment On Regulatory Notice 21-19
Lee Taylor Comment On Regulatory Notice 21-19
Bryce Phillips Comment On Regulatory Notice 21-19
Michael Ward Comment On Regulatory Notice 21-19
Christopher Bailey Comment On Regulatory Notice 21-19
Anonymous-AA Comment On Regulatory Notice 21-19
Christopher Comment On Regulatory Notice 21-19
Ken Tatis Comment On Regulatory Notice 21-19
Anonymous-MC Comment On Regulatory Notice 21-19
William Beard Comment On Regulatory Notice 21-19
Marty Bagasan Comment On Regulatory Notice 21-19
Mike Palacio Comment On Regulatory Notice 21-19
Aaron Gayle Comment On Regulatory Notice 21-19
Scott C Comment On Regulatory Notice 21-19
Adam Comment On Regulatory Notice 21-19
Julian Jones Comment On Regulatory Notice 21-19
Ty McComas Comment On Regulatory Notice 21-19
Birger Christan Comment On Regulatory Notice 21-19
Randall Panter Comment On Regulatory Notice 21-19
Nestor Montesino Comment On Regulatory Notice 21-19
Yamil Martin Comment On Regulatory Notice 21-19
Benjamin Fehling Comment On Regulatory Notice 21-19
Chris Sojka Comment On Regulatory Notice 21-19
Gordon Leonard Comment On Regulatory Notice 21-19
Matthew T Comment On Regulatory Notice 21-19
Land Folkes Comment On Regulatory Notice 21-19
Daniel Scott Edvalson Comment On Regulatory Notice 21-19
Nick Comment On Regulatory Notice 21-19
David Helton Comment On Regulatory Notice 21-19
Nathan Schmitz Comment On Regulatory Notice 21-19
Jaime Vintimilla Comment On Regulatory Notice 21-19
Michael Mosquito Comment On Regulatory Notice 21-19
Manuel Torres Comment On Regulatory Notice 21-19
Michael Wilson Comment On Regulatory Notice 21-19
Jon Jones Comment On Regulatory Notice 21-19
Julio Comment On Regulatory Notice 21-19
Sung Lim Comment On Regulatory Notice 21-19
Joe Clark Comment On Regulatory Notice 21-19
Wichai Lao Comment On Regulatory Notice 21-19
Jonathan Gedrich Comment On Regulatory Notice 21-19
Josh Aguilar Comment On Regulatory Notice 21-19
John Rangel Comment On Regulatory Notice 21-19
Randy Abbe Comment On Regulatory Notice 21-19
Anonymous-TP Comment On Regulatory Notice 21-19
Shane Hrabe Comment On Regulatory Notice 21-19
Steven Comment On Regulatory Notice 21-19
Aidan Coonan Comment On Regulatory Notice 21-19
Jacob Williamson Comment On Regulatory Notice 21-19
Ryan Snyder Comment On Regulatory Notice 21-19
Benjamin Glider Comment On Regulatory Notice 21-19
Chad Chen Comment On Regulatory Notice 21-19
Fox G Rockefeller Comment On Regulatory Notice 21-19
Sean Wilson Comment On Regulatory Notice 21-19
Perry Powell Comment On Regulatory Notice 21-19
Alex Oroszlan Comment On Regulatory Notice 21-19
Freddie Comment On Regulatory Notice 21-19
William Quirindongo Comment On Regulatory Notice 21-19
Anonymous-HF Comment On Regulatory Notice 21-19
Anonymous-GG Comment On Regulatory Notice 21-19
Kyle Pugh Comment On Regulatory Notice 21-19
Wayne Comment On Regulatory Notice 21-19
Ryan Reynolds Comment On Regulatory Notice 21-19
Spencer Lipkin Comment On Regulatory Notice 21-19
Nick Schwinghammer Comment On Regulatory Notice 21-19
Joe Comment On Regulatory Notice 21-19
Charlie Alexander Comment On Regulatory Notice 21-19
Robert Paulson Comment On Regulatory Notice 21-19
Jeremy Lewis Comment On Regulatory Notice 21-19
Claude Bingham Comment On Regulatory Notice 21-19
Michael Heagy Comment On Regulatory Notice 21-19
Chris Pollice Comment On Regulatory Notice 21-19
Sarah Fightmaster Comment On Regulatory Notice 21-19
Colton Glenn Comment On Regulatory Notice 21-19
Alex M Comment On Regulatory Notice 21-19
Manuel Torres Comment On Regulatory Notice 21-19
Dustin Gatlin Comment On Regulatory Notice 21-19
Anonymous-JB Comment On Regulatory Notice 21-19
Anonymous-MJ Comment On Regulatory Notice 21-19
Christopher Dubois Comment On Regulatory Notice 21-19
Nathan Schurr Comment On Regulatory Notice 21-19
Leonidas Georgiou Comment On Regulatory Notice 21-19
Madhva Gomez Comment On Regulatory Notice 21-19
Anisa Manion Comment On Regulatory Notice 21-19
Kai M Comment On Regulatory Notice 21-19
Ed Comment On Regulatory Notice 21-19
Chris Kerns Comment On Regulatory Notice 21-19
Joe Halliday Comment On Regulatory Notice 21-19
Justin Gallant Comment On Regulatory Notice 21-19
Mike Comment On Regulatory Notice 21-19
Avery Wyatt Comment On Regulatory Notice 21-19
Carlos Taveras Comment On Regulatory Notice 21-19
Richard Welsh Comment On Regulatory Notice 21-19
Fernie Muñoz Comment On Regulatory Notice 21-19
Kevin McCarte Comment On Regulatory Notice 21-19
Ian Gold Comment On Regulatory Notice 21-19
Joshua Hobbs Comment On Regulatory Notice 21-19
Jape Diamond Comment On Regulatory Notice 21-19
Alexander Gomez Comment On Regulatory Notice 21-19
Carlos Somarriba Comment On Regulatory Notice 21-19
Rob Arrick Comment On Regulatory Notice 21-19
Anonymous-NN Comment On Regulatory Notice 21-19
Liza Comment On Regulatory Notice 21-19
Anonymous-GM Comment On Regulatory Notice 21-19
Andy Comment On Regulatory Notice 21-19
Tyler D King Comment On Regulatory Notice 21-19
Homero Perez-Gomez Comment On Regulatory Notice 21-19
Oliver Comment On Regulatory Notice 21-19
Anthony Bailey Comment On Regulatory Notice 21-19
Greg A Antonucci Comment On Regulatory Notice 21-19
Brian Sapp Comment On Regulatory Notice 21-19
Phillip Bell Comment On Regulatory Notice 21-19
William Cowan Comment On Regulatory Notice 21-19
Joe Comment On Regulatory Notice 21-19
Michael Murphy Comment On Regulatory Notice 21-19
Mohamed Aboutaam Comment On Regulatory Notice 21-19
Cooper Coffey Comment On Regulatory Notice 21-19
Emmanuel Ibus Comment On Regulatory Notice 21-19
Joshua Bentley Comment On Regulatory Notice 21-19
Mark David Clarke Comment On Regulatory Notice 21-19
Zod Mansour Comment On Regulatory Notice 21-19
Richard Pinder Comment On Regulatory Notice 21-19
Anonymous-KT Comment On Regulatory Notice 21-19
Anonymous-BM Comment On Regulatory Notice 21-19
James Sanders Comment On Regulatory Notice 21-19
Dawn Monroe Comment On Regulatory Notice 21-19
Kevin Christensen Comment On Regulatory Notice 21-19
Anthony Vella Comment On Regulatory Notice 21-19
Jesse Comment On Regulatory Notice 21-19
Jason Skovronski Comment On Regulatory Notice 21-19
Michael Depke Comment On Regulatory Notice 21-19
C Derfler Comment On Regulatory Notice 21-19
Kevin King Comment On Regulatory Notice 21-19
Ed Comment On Regulatory Notice 21-19
Bilal Dia Comment On Regulatory Notice 21-19
Eric Ellsworth Comment On Regulatory Notice 21-19
Darrell Jones Comment On Regulatory Notice 21-19
George Pichirallo Comment On Regulatory Notice 21-19
Gregory S Bowman Comment On Regulatory Notice 21-19
John Pimentel Comment On Regulatory Notice 21-19
Chris Chambers Comment On Regulatory Notice 21-19
Mohamad Kanj Comment On Regulatory Notice 21-19
Anon Comment On Regulatory Notice 21-19
Mark Glor Comment On Regulatory Notice 21-19
Justin Nettles Comment On Regulatory Notice 21-19
James Kidd Comment On Regulatory Notice 21-19
Priambadha Soebiakto Comment On Regulatory Notice 21-19
Rhonda Banks Comment On Regulatory Notice 21-19
Joshua M Collins Comment On Regulatory Notice 21-19
Judy Calderon Comment On Regulatory Notice 21-19
Nik Comment On Regulatory Notice 21-19
Zack Clayton Comment On Regulatory Notice 21-19
Leonard Anthony Comment On Regulatory Notice 21-19
Justin Cabe Comment On Regulatory Notice 21-19
Jason Comment On Regulatory Notice 21-19
TaMyrah McTear Comment On Regulatory Notice 21-19
Ben Comment On Regulatory Notice 21-19
Timothy Hoovestol Comment On Regulatory Notice 21-19
Deonte Comment On Regulatory Notice 21-19
Emmanuel Ibus Comment On Regulatory Notice 21-19
Kevin Rockhill Comment On Regulatory Notice 21-19
Zach Philipps Comment On Regulatory Notice 21-19
Joe Daughtery Comment On Regulatory Notice 21-19
Jeremy Cornell Comment On Regulatory Notice 21-19
Íron Plunkett Comment On Regulatory Notice 21-19
Buddy Morsello Comment On Regulatory Notice 21-19
Bill Gutierrez Comment On Regulatory Notice 21-19
Christopher Comment On Regulatory Notice 21-19
Sterling Comment On Regulatory Notice 21-19
Saul Amaro Comment On Regulatory Notice 21-19
Rhonda K Kriesel Comment On Regulatory Notice 21-19
Mark Hughes Comment On Regulatory Notice 21-19
Anonymous-J Comment On Regulatory Notice 21-19
Zachary Comment On Regulatory Notice 21-19
Justin Comment On Regulatory Notice 21-19
Kevin Roberts Comment On Regulatory Notice 21-19
Michael Keller Comment On Regulatory Notice 21-19
Justin M Steikar Comment On Regulatory Notice 21-19
Jared Deal Comment On Regulatory Notice 21-19
Anonymous-R Comment On Regulatory Notice 21-19
Anonymous-AF Comment On Regulatory Notice 21-19
Nick Alfonso Comment On Regulatory Notice 21-19
Zachary Walker Comment On Regulatory Notice 21-19
David White Comment On Regulatory Notice 21-19
Darrell John Ramones Cayaban Comment On Regulatory Notice 21-19
Kelli H Brown Comment On Regulatory Notice 21-19
Eileen Loh Comment On Regulatory Notice 21-19
Evan Comment On Regulatory Notice 21-19
Raymond Bradley Beaudry Comment On Regulatory Notice 21-19
Ian Philpot Comment On Regulatory Notice 21-19
Walter Conklin Comment On Regulatory Notice 21-19
Anthony Grisanti II Comment On Regulatory Notice 21-19
Emerson Comment On Regulatory Notice 21-19
Christopher Uvanni Comment On Regulatory Notice 21-19
Riyad Shenar Comment On Regulatory Notice 21-19
Marcelo Erosa Comment On Regulatory Notice 21-19
Rickie Pauley Comment On Regulatory Notice 21-19
Anonymous-QB Comment On Regulatory Notice 21-19
Victor Comment On Regulatory Notice 21-19
Nalk Comment On Regulatory Notice 21-19
Daniel Muhlberger Comment On Regulatory Notice 21-19
Enrique Valadez Comment On Regulatory Notice 21-19
Hridaynag Kooretti Comment On Regulatory Notice 21-19
Anonymous-HM Comment On Regulatory Notice 21-19
Greg Mohan Comment On Regulatory Notice 21-19
Sasha Ford Comment On Regulatory Notice 21-19
Evan Wells Comment On Regulatory Notice 21-19
Johnathan Kim Comment On Regulatory Notice 21-19
Daniel Trotter Comment On Regulatory Notice 21-19
Dyl Pere Comment On Regulatory Notice 21-19
Anonymous-SC Comment On Regulatory Notice 21-19
JD Machalicek Comment On Regulatory Notice 21-19
Jimmy Pham Comment On Regulatory Notice 21-19
Tim Comment On Regulatory Notice 21-19
Randy Bishop Comment On Regulatory Notice 21-19
Chad A Burke Comment On Regulatory Notice 21-19
Arun Pradhanang Comment On Regulatory Notice 21-19
Russell Cohen Comment On Regulatory Notice 21-19
Isa Sabree Comment On Regulatory Notice 21-19
S-J Comment On Regulatory Notice 21-19
Tom Szaran Comment On Regulatory Notice 21-19
Jill Comment On Regulatory Notice 21-19
Adam Wilka Comment On Regulatory Notice 21-19
Alex Bursh Comment On Regulatory Notice 21-19
Del Schoening Comment On Regulatory Notice 21-19
Andres Gonzalez Comment On Regulatory Notice 21-19
Logan Peterson Comment On Regulatory Notice 21-19
Ben Roberts Comment On Regulatory Notice 21-19
Ryan Barstad Comment On Regulatory Notice 21-19
Jason Chamberlain Comment On Regulatory Notice 21-19
John Josma Comment On Regulatory Notice 21-19
Matthew Eschrich Comment On Regulatory Notice 21-19
Razvan G Comment On Regulatory Notice 21-19
Ryan Davey Comment On Regulatory Notice 21-19
Stephen Deane Comment On Regulatory Notice 21-19
Joe S Comment On Regulatory Notice 21-19
James Townsend Comment On Regulatory Notice 21-19
James Comment On Regulatory Notice 21-19
Julian Comment On Regulatory Notice 21-19
Kyle Comment On Regulatory Notice 21-19
Porter McManus Comment On Regulatory Notice 21-19
Alexia Eroglu Comment On Regulatory Notice 21-19
T. Amir Comment On Regulatory Notice 21-19
Kenny Seagle Comment On Regulatory Notice 21-19
Richard Bertin Comment On Regulatory Notice 21-19
Anonymous-AAC Comment On Regulatory Notice 21-19
Bartholomew Comment On Regulatory Notice 21-19
Amy Hallowell Comment On Regulatory Notice 21-19
Benjamin Moroni Comment On Regulatory Notice 21-19
Jesse Adams Comment On Regulatory Notice 21-19
Francis Schweitzer Comment On Regulatory Notice 21-19
Zachary W Walker Comment On Regulatory Notice 21-19
Kevin Villar Comment On Regulatory Notice 21-19
Lucas Kolasa Comment On Regulatory Notice 21-19
Jason Acevedo Comment On Regulatory Notice 21-19
Christopher Fisher Comment On Regulatory Notice 21-19
James Case Comment On Regulatory Notice 21-19
Mike Flamm Comment On Regulatory Notice 21-19
Thomas Duggan Comment On Regulatory Notice 21-19
Macbolan Comment On Regulatory Notice 21-19
TGM Comment On Regulatory Notice 21-19
Kasper Anderson Comment On Regulatory Notice 21-19
Steven R Linderman Comment On Regulatory Notice 21-19
Paul Carmon Comment On Regulatory Notice 21-19
Michael Comment On Regulatory Notice 21-19
Emmanuel Ibus Comment On Regulatory Notice 21-19
Matthew DiGiacomo Comment On Regulatory Notice 21-19
Ty P Comment On Regulatory Notice 21-19
Greg Erin Comment On Regulatory Notice 21-19
Cesar Comment On Regulatory Notice 21-19
Anonymous-AB Comment On Regulatory Notice 21-19
Raynald A Carre Comment On Regulatory Notice 21-19
Jay Ulwelling Comment On Regulatory Notice 21-19
Derek Smith Comment On Regulatory Notice 21-19
Dan M Maloney Comment On Regulatory Notice 21-19
Ron Velotta Comment On Regulatory Notice 21-19
Anonymous-BO Comment On Regulatory Notice 21-19
Anonymous-LS Comment On Regulatory Notice 21-19
Joseph Christoni Comment On Regulatory Notice 21-19
Marco Mendoza Comment On Regulatory Notice 21-19
Matt Kowalski Comment On Regulatory Notice 21-19
Josh Shipley Comment On Regulatory Notice 21-19
Jill Lundin Comment On Regulatory Notice 21-19
Dan Leuthner Comment On Regulatory Notice 21-19
Ken Szymczyk Comment On Regulatory Notice 21-19
Jacob Comment On Regulatory Notice 21-19
Michael Miller Comment On Regulatory Notice 21-19
John M Comment On Regulatory Notice 21-19
Neil Gillman Comment On Regulatory Notice 21-19
Kevin Tedesco Comment On Regulatory Notice 21-19
Chris Comment On Regulatory Notice 21-19
Raymond Toledo Comment On Regulatory Notice 21-19
Diego Rivera Comment On Regulatory Notice 21-19
Adam Oester Comment On Regulatory Notice 21-19
Alina Palade Comment On Regulatory Notice 21-19
Wally Luckeydoo Comment On Regulatory Notice 21-19
Ron Sisk Comment On Regulatory Notice 21-19
Jim Kukunis Comment On Regulatory Notice 21-19
Jose Acosta Comment On Regulatory Notice 21-19
Dominik Comment On Regulatory Notice 21-19
Sheldon Branche Comment On Regulatory Notice 21-19
James Ochner Comment On Regulatory Notice 21-19
Carl Halpin Comment On Regulatory Notice 21-19
James Cushman Comment On Regulatory Notice 21-19
John Smythe Comment On Regulatory Notice 21-19
Robert Saylor Comment On Regulatory Notice 21-19
Timothy Siar Comment On Regulatory Notice 21-19
Dyami Comment On Regulatory Notice 21-19
Andrew Labbee Comment On Regulatory Notice 21-19
Anonymous-DM Comment On Regulatory Notice 21-19
Bianca Ramjit Comment On Regulatory Notice 21-19
Sumita Comment On Regulatory Notice 21-19
Kevin Ortegel Comment On Regulatory Notice 21-19
Stephon Danner Comment On Regulatory Notice 21-19
Anonymous-AD Comment On Regulatory Notice 21-19
Rachel Comment On Regulatory Notice 21-19
Chris Romme Comment On Regulatory Notice 21-19
Michael Mourachian Comment On Regulatory Notice 21-19
Yessica Amaya Comment On Regulatory Notice 21-19
Anonymous-MP Comment On Regulatory Notice 21-19
Jason Cole Comment On Regulatory Notice 21-19
Addison Weakland Comment On Regulatory Notice 21-19
Shawn Kargel Comment On Regulatory Notice 21-19
Richard Quick Comment On Regulatory Notice 21-19
Frank Brown Comment On Regulatory Notice 21-19
Harry Borchers Comment On Regulatory Notice 21-19
Anonymous-R Comment On Regulatory Notice 21-19
Jharvis Licera Comment On Regulatory Notice 21-19
Philip Bennett Comment On Regulatory Notice 21-19
D Lione Comment On Regulatory Notice 21-19
Ryan Cantrell Comment On Regulatory Notice 21-19
Anonymous-FVT Comment On Regulatory Notice 21-19
Kenny Orellana Comment On Regulatory Notice 21-19
Aleksa Cajic Comment On Regulatory Notice 21-19
Anonymous-SB Comment On Regulatory Notice 21-19
Darryn Felton Comment On Regulatory Notice 21-19
Nern Sasi Comment On Regulatory Notice 21-19
Timothy Pope Comment On Regulatory Notice 21-19
Paul Molina Comment On Regulatory Notice 21-19
Anonymous-DB Comment On Regulatory Notice 21-19
Charles McChargue Comment On Regulatory Notice 21-19
Brycon Calhoun Comment On Regulatory Notice 21-19
Balazs Szemann Comment On Regulatory Notice 21-19
Gage Torres Comment On Regulatory Notice 21-19
Francis Clark Comment On Regulatory Notice 21-19
Simon Biddlecombe Comment On Regulatory Notice 21-19
Brian Unruh Comment On Regulatory Notice 21-19
Torries D Gunn Comment On Regulatory Notice 21-19
Dave Starke Comment On Regulatory Notice 21-19
Emmanuel Ibus Comment On Regulatory Notice 21-19
Rianna R Vilaire Comment On Regulatory Notice 21-19
Ryan Staggs Comment On Regulatory Notice 21-19
Justin Comment On Regulatory Notice 21-19
Jesse Harmon Comment On Regulatory Notice 21-19
Branden Comment On Regulatory Notice 21-19
Ricky Belmontes Comment On Regulatory Notice 21-19
Scott Fedor Comment On Regulatory Notice 21-19
Nolan Hernaez Comment On Regulatory Notice 21-19
Hayden Thompson Comment On Regulatory Notice 21-19
Justin Schumann Comment On Regulatory Notice 21-19
Kristopher Thibert Comment On Regulatory Notice 21-19
Kelley Hancock Comment On Regulatory Notice 21-19
Aaron Borg Comment On Regulatory Notice 21-19
Ben Dye Comment On Regulatory Notice 21-19
Clarence V Partridge III Comment On Regulatory Notice 21-19
Paula Parker Comment On Regulatory Notice 21-19
Jason Hiser Comment On Regulatory Notice 21-19
Rich Kaiser Comment On Regulatory Notice 21-19
James Livingston Comment On Regulatory Notice 21-19
Bonnie Pettis Comment On Regulatory Notice 21-19
Jay Singh Comment On Regulatory Notice 21-19
Margie Sheehan Comment On Regulatory Notice 21-19
Steven A Comment On Regulatory Notice 21-19
Anonymous-OD Comment On Regulatory Notice 21-19
Michael Depke Comment On Regulatory Notice 21-19
Daniel Abraham Comment On Regulatory Notice 21-19
Luis Pineda Comment On Regulatory Notice 21-19
Tam Tran Comment On Regulatory Notice 21-19
Bill Dudley Comment On Regulatory Notice 21-19
Kenneth Cook Comment On Regulatory Notice 21-19
Anonymous-JG Comment On Regulatory Notice 21-19
Brandon Morin Comment On Regulatory Notice 21-19
Karl Allan Comment On Regulatory Notice 21-19
Nathan Christopher Schoenfeld Comment On Regulatory Notice 21-19
Carlos Medina Comment On Regulatory Notice 21-19
Victor Martinez Comment On Regulatory Notice 21-19
Daniel Carter Comment On Regulatory Notice 21-19
Dia Michelle Comment On Regulatory Notice 21-19
Frankie Jobe Comment On Regulatory Notice 21-19
James Bryan Needham Comment On Regulatory Notice 21-19
John Kozubal Comment On Regulatory Notice 21-19
Ronny Cornell Comment On Regulatory Notice 21-19
Anonymous-SD Comment On Regulatory Notice 21-19
Flavian Dioscuri Comment On Regulatory Notice 21-19
Robert Baxa Comment On Regulatory Notice 21-19
Lynn Barry Comment On Regulatory Notice 21-19
Nicholas LaBelle Comment On Regulatory Notice 21-19
Oland Smith Comment On Regulatory Notice 21-19
Lawrence Jacobs Comment On Regulatory Notice 21-19
Anonymous-V Comment On Regulatory Notice 21-19
Goodson Comment On Regulatory Notice 21-19
Anonymous-KW Comment On Regulatory Notice 21-19
Gary Butcher Comment On Regulatory Notice 21-19
Manuel Martinez Comment On Regulatory Notice 21-19
Drew M Comment On Regulatory Notice 21-19
Lucas Comment On Regulatory Notice 21-19
Charles B Mundorf Comment On Regulatory Notice 21-19
Aaron B Comment On Regulatory Notice 21-19
Anthony Comment On Regulatory Notice 21-19
Chris Chandler Comment On Regulatory Notice 21-19
Pete Comment On Regulatory Notice 21-19
Stephen T Lee Comment On Regulatory Notice 21-19
William Roberts Comment On Regulatory Notice 21-19
Alfredo Izquierdo Comment On Regulatory Notice 21-19
Magnus Henningsson Comment On Regulatory Notice 21-19
Jared Zeiders Comment On Regulatory Notice 21-19
Darin Harper Comment On Regulatory Notice 21-19
Anonymous-C Comment On Regulatory Notice 21-19
Kristopher Castilho Comment On Regulatory Notice 21-19
Adrian Palmer Comment On Regulatory Notice 21-19
Richard McKee Comment On Regulatory Notice 21-19
Michelle Comment On Regulatory Notice 21-19
Kyle Stevens Comment On Regulatory Notice 21-19
Ric Pennington Comment On Regulatory Notice 21-19
Hulk Hagrid Comment On Regulatory Notice 21-19
Kyle Johnson Comment On Regulatory Notice 21-19
Bouajila Comment On Regulatory Notice 21-19
Nam Comment On Regulatory Notice 21-19
Anonymous-C Comment On Regulatory Notice 21-19
Jack Hosler Comment On Regulatory Notice 21-19
Anonymous-AB Comment On Regulatory Notice 21-19
Anonymous-JN Comment On Regulatory Notice 21-19
Anonymous-M Comment On Regulatory Notice 21-19
Ernesto Blanco Comment On Regulatory Notice 21-19
Mike Comment On Regulatory Notice 21-19
Charles Guerrieri JR Comment On Regulatory Notice 21-19
Mitchell Krenek Comment On Regulatory Notice 21-19
Lorie Luzarraga Comment On Regulatory Notice 21-19
Nunya Comment On Regulatory Notice 21-19
Felipe Borges Comment On Regulatory Notice 21-19
Daniel VanEpps Comment On Regulatory Notice 21-19
Jamie Heeg Comment On Regulatory Notice 21-19
Derek J. Fuller Comment On Regulatory Notice 21-19
Rami Ezzeldin Barakat Comment On Regulatory Notice 21-19
Marc Comment On Regulatory Notice 21-19
Anonymous-RL Comment On Regulatory Notice 21-19
Edward Williams Comment On Regulatory Notice 21-19
Anonymous-AI Comment On Regulatory Notice 21-19
Kelli Brost Comment On Regulatory Notice 21-19
Will Comment On Regulatory Notice 21-19
Glenn Basgaard Comment On Regulatory Notice 21-19
John C McKenna Comment On Regulatory Notice 21-19
Sergio Gonzalez Comment On Regulatory Notice 21-19
Jason Tabar Comment On Regulatory Notice 21-19
Matt Comment On Regulatory Notice 21-19
Pedro Rodriguez Comment On Regulatory Notice 21-19
Joseph Williams Comment On Regulatory Notice 21-19
Mark Burpee Comment On Regulatory Notice 21-19
Anonymous-AM Comment On Regulatory Notice 21-19
Nathan Watkins Comment On Regulatory Notice 21-19
Patricia Jamison Comment On Regulatory Notice 21-19
Timothy Autin Comment On Regulatory Notice 21-19
Andrew Simpson Comment On Regulatory Notice 21-19
Samuel Ghabrial Comment On Regulatory Notice 21-19
Emmanuel Ibus Comment On Regulatory Notice 21-19
Shawn Polivoi Comment On Regulatory Notice 21-19
Matthew Johnson Comment On Regulatory Notice 21-19
Christina Buccafurni Comment On Regulatory Notice 21-19
Anonymous-J Comment On Regulatory Notice 21-19
Mike Comment On Regulatory Notice 21-19
Chloe Comment On Regulatory Notice 21-19
Archer Comment On Regulatory Notice 21-19
Anonymous-JB Comment On Regulatory Notice 21-19
I.C. Barthle Comment On Regulatory Notice 21-19
Anonymous-SP Comment On Regulatory Notice 21-19
Gavin Stobbart Comment On Regulatory Notice 21-19
Matt Caucci Comment On Regulatory Notice 21-19
Jarrett Quintero Comment On Regulatory Notice 21-19
Justin Lee Porter Comment On Regulatory Notice 21-19
Belbiv Deveau Comment On Regulatory Notice 21-19
Charles Abel Comment On Regulatory Notice 21-19
Andrea Hazard Comment On Regulatory Notice 21-19
Jamie Marciok Comment On Regulatory Notice 21-19
Emmanuel Ibus Comment On Regulatory Notice 21-19
Ryan James Comment On Regulatory Notice 21-19
James Harris Comment On Regulatory Notice 21-19
Phillip Gurgone Comment On Regulatory Notice 21-19
Bailey Ponder Comment On Regulatory Notice 21-19
Ryan Comment On Regulatory Notice 21-19
Mary Eileen Gardner Comment On Regulatory Notice 21-19
Hongzhi Zhang Comment On Regulatory Notice 21-19
Roderick Murphy Comment On Regulatory Notice 21-19
Troy Homa Comment On Regulatory Notice 21-19
Jonathan Gedrich Comment On Regulatory Notice 21-19
Anonymous-TD Comment On Regulatory Notice 21-19
Sue Atherton Comment On Regulatory Notice 21-19
Ryan French Comment On Regulatory Notice 21-19
Cole Evans Comment On Regulatory Notice 21-19
Andrew Hickey Comment On Regulatory Notice 21-19
Anonymous-P Comment On Regulatory Notice 21-19
Greg Rollins Comment On Regulatory Notice 21-19
Sarah Buro Comment On Regulatory Notice 21-19
Jonathan Hernandez Comment On Regulatory Notice 21-19
Matthias Siebert Comment On Regulatory Notice 21-19
Kevin Comment On Regulatory Notice 21-19
Anonymous-RT Comment On Regulatory Notice 21-19
Doug Riley Comment On Regulatory Notice 21-19
Garith Smith Comment On Regulatory Notice 21-19
Robert Wasik Comment On Regulatory Notice 21-19
Patrick Ayers Comment On Regulatory Notice 21-19
Jessy Padgett Comment On Regulatory Notice 21-19
Marcel Kuhl Comment On Regulatory Notice 21-19
Antonio Gatto Comment On Regulatory Notice 21-19
Michael Griffith Comment On Regulatory Notice 21-19
Anonymous-SO Comment On Regulatory Notice 21-19
Emil Dahm Comment On Regulatory Notice 21-19
Joseph Norman Comment On Regulatory Notice 21-19
Hayden Williams Comment On Regulatory Notice 21-19
Anonymous-AR Comment On Regulatory Notice 21-19
Jeff Cody Comment On Regulatory Notice 21-19
Kyle Bingaman Comment On Regulatory Notice 21-19
James Patterson Comment On Regulatory Notice 21-19
Nico Gee Comment On Regulatory Notice 21-19
Steven Zmrazek Comment On Regulatory Notice 21-19
Andres Rodriguez Comment On Regulatory Notice 21-19
Anonymous-WS Comment On Regulatory Notice 21-19
Hunter D Hopkins Comment On Regulatory Notice 21-19
Christopher Reed Comment On Regulatory Notice 21-19
Jeffrey Quezada Comment On Regulatory Notice 21-19
Holin Hong Comment On Regulatory Notice 21-19
Anonymous-T Comment On Regulatory Notice 21-19
Ryan C Comment On Regulatory Notice 21-19
Noah Ritter Comment On Regulatory Notice 21-19
Alexander Wolf Comment On Regulatory Notice 21-19
Dave Ulloa Comment On Regulatory Notice 21-19
Christopher Kelly Comment On Regulatory Notice 21-19
Rayne Overall Comment On Regulatory Notice 21-19
Daniel Bostelmann Comment On Regulatory Notice 21-19
Tom Arkus Comment On Regulatory Notice 21-19
Anonymous-MB Comment On Regulatory Notice 21-19
Tim Crawford Comment On Regulatory Notice 21-19
Hieu Le Comment On Regulatory Notice 21-19
Minh Nguyen Comment On Regulatory Notice 21-19
Jack Bauman Comment On Regulatory Notice 21-19
Keyton Gibson Comment On Regulatory Notice 21-19
John Backus Comment On Regulatory Notice 21-19
Joseph Leos Comment On Regulatory Notice 21-19
Jonathan Wolanyk Comment On Regulatory Notice 21-19
Mario Quintero Comment On Regulatory Notice 21-19
Michael Ruyle Comment On Regulatory Notice 21-19
Mike Garske Comment On Regulatory Notice 21-19
Eric Ory Comment On Regulatory Notice 21-19
Justin Darrow Comment On Regulatory Notice 21-19
Paul DiCicco Comment On Regulatory Notice 21-19
David Gross Comment On Regulatory Notice 21-19
Anonymous-BS Comment On Regulatory Notice 21-19
Lee Hunter Comment On Regulatory Notice 21-19
Nichole Ruggiero Comment On Regulatory Notice 21-19
Kenneth Fleming Comment On Regulatory Notice 21-19
Neil Parker Comment On Regulatory Notice 21-19
Marino Robles Comment On Regulatory Notice 21-19
Ilde Senesence Comment On Regulatory Notice 21-19
Anonymous-C Comment On Regulatory Notice 21-19
Christian Tanner Comment On Regulatory Notice 21-19
Sara Venice Comment On Regulatory Notice 21-19
D.B. Comment On Regulatory Notice 21-19
Chad Guinn Comment On Regulatory Notice 21-19
Jim Cirimele Comment On Regulatory Notice 21-19
George Hadjichristou Comment On Regulatory Notice 21-19
Felipe Borges Comment On Regulatory Notice 21-19
Katarzyna Szczeszka Comment On Regulatory Notice 21-19
Mike Comment On Regulatory Notice 21-19
Chris Fox Comment On Regulatory Notice 21-19
Paul Kraetsch Comment On Regulatory Notice 21-19
Jimmy Harper Comment On Regulatory Notice 21-19
Gabriel Libanio Comment On Regulatory Notice 21-19
Rob Snow Comment On Regulatory Notice 21-19
Nick Wellman Comment On Regulatory Notice 21-19
Robert Norris Comment On Regulatory Notice 21-19
Paul Pritchard Comment On Regulatory Notice 21-19
Anisa Manion Comment On Regulatory Notice 21-19
Jhon Luke Cudiamat Comment On Regulatory Notice 21-19
Eric G Comment On Regulatory Notice 21-19
Nick Ward Comment On Regulatory Notice 21-19
Paul O’Toole Comment On Regulatory Notice 21-19
Michael Lee Comment On Regulatory Notice 21-19
Rob Sparks Comment On Regulatory Notice 21-19
Thomas Chelly Comment On Regulatory Notice 21-19
Soren Silkenson Comment On Regulatory Notice 21-19
David Murray Comment On Regulatory Notice 21-19
Kyle Hewett Comment On Regulatory Notice 21-19
Emmanuel Ibus Comment On Regulatory Notice 21-19
Anonymous-EZ Comment On Regulatory Notice 21-19
David Kotewa Comment On Regulatory Notice 21-19
Alexander Leith Comment On Regulatory Notice 21-19
Erick Keller Comment On Regulatory Notice 21-19
Terriona Sherrod Comment On Regulatory Notice 21-19
John Comment On Regulatory Notice 21-19
Phil S Scott Jr Comment On Regulatory Notice 21-19
David M Comment On Regulatory Notice 21-19
Jensen Comment On Regulatory Notice 21-19
Jessica Pett Comment On Regulatory Notice 21-19
Valerie L Barela Comment On Regulatory Notice 21-19
Josiah Anderson Comment On Regulatory Notice 21-19
Grant Deslauriers Comment On Regulatory Notice 21-19
Tyler MacIntosh Comment On Regulatory Notice 21-19
Anthony Mazzola Comment On Regulatory Notice 21-19
Anonymous-RB Comment On Regulatory Notice 21-19
Kevin Moreno Comment On Regulatory Notice 21-19
Yohannes Berhane Comment On Regulatory Notice 21-19
Vang Her Comment On Regulatory Notice 21-19
Jordan G Comment On Regulatory Notice 21-19
Jacob D Varble Comment On Regulatory Notice 21-19
Derrikk Ray Comment On Regulatory Notice 21-19
Tina Nasr Comment On Regulatory Notice 21-19
Daniel Rönsholdt Comment On Regulatory Notice 21-19
Anonymous-AH Comment On Regulatory Notice 21-19
Christopher T Funakoshi Comment On Regulatory Notice 21-19
Karl Son Comment On Regulatory Notice 21-19
Sam Park Comment On Regulatory Notice 21-19
Nicholas LaBelle Comment On Regulatory Notice 21-19
Justin Geronsin Comment On Regulatory Notice 21-19
Sarina Sdeung Comment On Regulatory Notice 21-19
Chad Thomas Comment On Regulatory Notice 21-19
Andrew Johnsen Comment On Regulatory Notice 21-19
John Antunes Comment On Regulatory Notice 21-19
Donnie R Lee Comment On Regulatory Notice 21-19
Samuel Sisco Comment On Regulatory Notice 21-19
Shaun Smith Comment On Regulatory Notice 21-19
John Malpas Comment On Regulatory Notice 21-19
Paul Comment On Regulatory Notice 21-19
T.C. Henley Comment On Regulatory Notice 21-19
Paul B Kraetsch Comment On Regulatory Notice 21-19
Carter Sanders Comment On Regulatory Notice 21-19
Jason Cory Comment On Regulatory Notice 21-19
Christopher Wang Comment On Regulatory Notice 21-19
Jeffrey Cline Comment On Regulatory Notice 21-19
Enrique Varas Comment On Regulatory Notice 21-19
Jeffrey Romero Comment On Regulatory Notice 21-19
Daniel Low Comment On Regulatory Notice 21-19
Chris Siebeneicher Comment On Regulatory Notice 21-19
Vlad Osadchyy Comment On Regulatory Notice 21-19
Danny Yelland Comment On Regulatory Notice 21-19
Justin Martin Comment On Regulatory Notice 21-19
R. Wolfe Comment On Regulatory Notice 21-19
Marshall Waters Comment On Regulatory Notice 21-19
Dylan Waldner Comment On Regulatory Notice 21-19
Anonymous-BD Comment On Regulatory Notice 21-19
Michael Ott Comment On Regulatory Notice 21-19
Miguel Gonzalez Comment On Regulatory Notice 21-19
Scarlett Lovell Comment On Regulatory Notice 21-19
Finn Heckenroth Comment On Regulatory Notice 21-19
J P Comment On Regulatory Notice 21-19
Matthew Haid Comment On Regulatory Notice 21-19
Michael C Hinson Comment On Regulatory Notice 21-19
Clarisse Joy De Guia Comment On Regulatory Notice 21-19
Logan Demeny Comment On Regulatory Notice 21-19
Tiernan Rae Comment On Regulatory Notice 21-19
Tania G Comment On Regulatory Notice 21-19
Jay Akhtar Comment On Regulatory Notice 21-19
Matt Comment On Regulatory Notice 21-19
Calvin Tran Comment On Regulatory Notice 21-19
Federico Lemmen Meyer Comment On Regulatory Notice 21-19
Ronnie Sparks Comment On Regulatory Notice 21-19
William J Butler Comment On Regulatory Notice 21-19
Jake N Comment On Regulatory Notice 21-19
Kane S Franklin Comment On Regulatory Notice 21-19
Michael Butler Comment On Regulatory Notice 21-19
Cory Conway Comment On Regulatory Notice 21-19
Neil Robertson Comment On Regulatory Notice 21-19
Kyle A Termini Comment On Regulatory Notice 21-19
Ricardo Ruvalcaba Ruiz Comment On Regulatory Notice 21-19
Todd Belgum Comment On Regulatory Notice 21-19
Tony Comment On Regulatory Notice 21-19
Jerome Casper Comment On Regulatory Notice 21-19
Kyle Comment On Regulatory Notice 21-19
Bill Oglesby Comment On Regulatory Notice 21-19
Andrew Thomas Comment On Regulatory Notice 21-19
Anonymous-JF Comment On Regulatory Notice 21-19
Daniel Batchelor Comment On Regulatory Notice 21-19
Christopher Oliveira Comment On Regulatory Notice 21-19
Sahil Comment On Regulatory Notice 21-19
Jessica N Krohn Comment On Regulatory Notice 21-19
Anonymous-RAU Comment On Regulatory Notice 21-19
Anonymous-RR Comment On Regulatory Notice 21-19
Christopher Funakoshi Comment On Regulatory Notice 21-19
Scott Green Comment On Regulatory Notice 21-19
Shree Krishna Dhital Comment On Regulatory Notice 21-19
Brandon Sullivan Comment On Regulatory Notice 21-19
Rocque Sandoval Comment On Regulatory Notice 21-19
Jerome El Kholi Comment On Regulatory Notice 21-19
Jay Comment On Regulatory Notice 21-19
Jonathan Gedrich Comment On Regulatory Notice 21-19
Anonymous-HJ Comment On Regulatory Notice 21-19
Jay O. Comment On Regulatory Notice 21-19
Philip Giacomantonio Comment On Regulatory Notice 21-19
Nathan Comment On Regulatory Notice 21-19
Anonymous-CM Comment On Regulatory Notice 21-19
Robert Brulinski Comment On Regulatory Notice 21-19
Molly Murphy Comment On Regulatory Notice 21-19
Shawn M Reeder Comment On Regulatory Notice 21-19
Nick Gaynier Comment On Regulatory Notice 21-19
Nimesh Panchal Comment On Regulatory Notice 21-19
Mahmoud Ibrahim Comment On Regulatory Notice 21-19
Jun Choi Comment On Regulatory Notice 21-19
Son Vo Comment On Regulatory Notice 21-19
Tanner Ryan Comment On Regulatory Notice 21-19
Anonymous-PW Comment On Regulatory Notice 21-19
Rory S Jenkins Comment On Regulatory Notice 21-19
Scott Miller Comment On Regulatory Notice 21-19
Gino Petrosian Comment On Regulatory Notice 21-19
Marcus Moore Comment On Regulatory Notice 21-19
Ridwan Odesanya Comment On Regulatory Notice 21-19
Lee Cox Comment On Regulatory Notice 21-19
David Taxer Comment On Regulatory Notice 21-19
Jonathan Ivan Velasquez Comment On Regulatory Notice 21-19
Heinrich Fan Comment On Regulatory Notice 21-19
James Prater Comment On Regulatory Notice 21-19
John Johnson Comment On Regulatory Notice 21-19
Brenda Lee Comment On Regulatory Notice 21-19
Brandon Liukko Comment On Regulatory Notice 21-19
James Erskine Comment On Regulatory Notice 21-19
Anonymous-DR Comment On Regulatory Notice 21-19
Matt Shonk Comment On Regulatory Notice 21-19
Greg Clemmons Comment On Regulatory Notice 21-19
Anonymous-CL Comment On Regulatory Notice 21-19
Verity Auden-Stevens Comment On Regulatory Notice 21-19
Tonya Lynn Salinas Comment On Regulatory Notice 21-19
Darius Roberts Comment On Regulatory Notice 21-19
Lorenzo Szentarioze Comment On Regulatory Notice 21-19
Anonymous-JS Comment On Regulatory Notice 21-19
Author Taylor Comment On Regulatory Notice 21-19
Lexi Comment On Regulatory Notice 21-19
Josh Comment On Regulatory Notice 21-19
James Courville Comment On Regulatory Notice 21-19
Ian Collado Comment On Regulatory Notice 21-19
Colin McFadden Comment On Regulatory Notice 21-19
William VanDelinder Comment On Regulatory Notice 21-19
Will Daniels Comment On Regulatory Notice 21-19
Damian Yeoman Comment On Regulatory Notice 21-19
Chris Colledge Comment On Regulatory Notice 21-19
Katie Harrison Comment On Regulatory Notice 21-19
William Whitby Comment On Regulatory Notice 21-19
Keoshia Jackson Comment On Regulatory Notice 21-19
Carl Davis Comment On Regulatory Notice 21-19
Gabe Feinberg Comment On Regulatory Notice 21-19
Hugo Andrade Comment On Regulatory Notice 21-19
Stephan Haefliger Comment On Regulatory Notice 21-19
Scott Comment On Regulatory Notice 21-19
William B Comment On Regulatory Notice 21-19
Aneil Mallavarapu Comment On Regulatory Notice 21-19
Ashton Parker Comment On Regulatory Notice 21-19
Kathryn Le Comment On Regulatory Notice 21-19
Sebastian Koehler Comment On Regulatory Notice 21-19
Nicholas Galanin Comment On Regulatory Notice 21-19
Christian Schickinger Comment On Regulatory Notice 21-19
Samuel Wildt Comment On Regulatory Notice 21-19
Anonymous-C Comment On Regulatory Notice 21-19
Tim Comment On Regulatory Notice 21-19
Bruce Lewis Comment On Regulatory Notice 21-19
Dean Choi Comment On Regulatory Notice 21-19
Justin Ross Comment On Regulatory Notice 21-19
Thomas B Comment On Regulatory Notice 21-19
Greg Clemmons Comment On Regulatory Notice 21-19
Victoria Shendock Comment On Regulatory Notice 21-19
Will Erdmann Comment On Regulatory Notice 21-19
Matthew Boggs Comment On Regulatory Notice 21-19
James Roberts Comment On Regulatory Notice 21-19
Brandon Thompson Comment On Regulatory Notice 21-19
Christopher Michael Lawrence Comment On Regulatory Notice 21-19
John Garland Comment On Regulatory Notice 21-19
Julian Caguin Comment On Regulatory Notice 21-19
Anonymous-SM Comment On Regulatory Notice 21-19
David Tuttman Comment On Regulatory Notice 21-19
Chance Lacour Comment On Regulatory Notice 21-19
Dick Cashman Comment On Regulatory Notice 21-19
Carl Davis Comment On Regulatory Notice 21-19
Kenneth Hughes Comment On Regulatory Notice 21-19
Emily Grieger Comment On Regulatory Notice 21-19
Allen C Comment On Regulatory Notice 21-19
Ardele Steele Comment On Regulatory Notice 21-19
William Comment On Regulatory Notice 21-19
Cristian Coianiz Comment On Regulatory Notice 21-19
Sam Comment On Regulatory Notice 21-19
Anonymous-KD Comment On Regulatory Notice 21-19
David Caradonna Comment On Regulatory Notice 21-19
Benjamin Roberts Comment On Regulatory Notice 21-19
Ruey Chang Comment On Regulatory Notice 21-19
Blair Westmoreland Comment On Regulatory Notice 21-19
Wing H Comment On Regulatory Notice 21-19
Michael Moreira Comment On Regulatory Notice 21-19
Vill-EOO Comment On Regulatory Notice 21-19
Nick Fory Comment On Regulatory Notice 21-19
Gary Lacy Comment On Regulatory Notice 21-19
Javier González Piqueras Comment On Regulatory Notice 21-19
Jason Wang Comment On Regulatory Notice 21-19
Justin Schuttenhelm Comment On Regulatory Notice 21-19
Thaddeus Rudd Comment On Regulatory Notice 21-19
J Kim Comment On Regulatory Notice 21-19
Selvam Venkatachalam Comment On Regulatory Notice 21-19
Luca Haverkate Comment On Regulatory Notice 21-19
Corinne Comment On Regulatory Notice 21-19
Fabian Comment On Regulatory Notice 21-19
Luke Sheldon Comment On Regulatory Notice 21-19
Marshall W Waters Comment On Regulatory Notice 21-19
John D Kirby Comment On Regulatory Notice 21-19
Michael Steinhauer Comment On Regulatory Notice 21-19
Keith Killian Comment On Regulatory Notice 21-19
Abraham Luna Perez Comment On Regulatory Notice 21-19
Jesse Thacher Comment On Regulatory Notice 21-19
Anonymous-ME Comment On Regulatory Notice 21-19
Thijs Sillen Comment On Regulatory Notice 21-19
Allen Harper Comment On Regulatory Notice 21-19
Nick Arens Comment On Regulatory Notice 21-19
Donaldson Santiago Comment On Regulatory Notice 21-19
Mike Comment On Regulatory Notice 21-19
Joseph R Lachance, Jr Comment On Regulatory Notice 21-19
Capone Stephen Comment On Regulatory Notice 21-19
Addam Stevens Comment On Regulatory Notice 21-19
Anonymous-CP Comment On Regulatory Notice 21-19
Jovani Morales Comment On Regulatory Notice 21-19
John R. Stoltenberg Comment On Regulatory Notice 21-19
Michael Baker Comment On Regulatory Notice 21-19
Ramon Tomzer Comment On Regulatory Notice 21-19
Josh Bayne Comment On Regulatory Notice 21-19
Christopher Thrasher Comment On Regulatory Notice 21-19
Jon Ramsey Comment On Regulatory Notice 21-19
Gustavo Vazquez Comment On Regulatory Notice 21-19
Xavier Wilson Comment On Regulatory Notice 21-19
Ryan Martin Comment On Regulatory Notice 21-19
Colin Riordan Comment On Regulatory Notice 21-19
Daron Sterling Comment On Regulatory Notice 21-19
John Comment On Regulatory Notice 21-19
Dave Comment On Regulatory Notice 21-19
Anum Comment On Regulatory Notice 21-19
Stephen Johnson Comment On Regulatory Notice 21-19
Karen Gaur Comment On Regulatory Notice 21-19
Erik Lage Comment On Regulatory Notice 21-19
Dillon Clanton Comment On Regulatory Notice 21-19
Lou Comment On Regulatory Notice 21-19
Kenneth V Lahr Comment On Regulatory Notice 21-19
Luis G Mejia Comment On Regulatory Notice 21-19
Staci Melton Comment On Regulatory Notice 21-19
Timothy W Rennels Comment On Regulatory Notice 21-19
Kris B Comment On Regulatory Notice 21-19
Alvin Williams Comment On Regulatory Notice 21-19
Ryan Comment On Regulatory Notice 21-19
Adam Comment On Regulatory Notice 21-19
Manuel Garcia Comment On Regulatory Notice 21-19
Trisha Comment On Regulatory Notice 21-19
Drew P. Comment On Regulatory Notice 21-19
Tom Berwick Comment On Regulatory Notice 21-19
Matthew Lenz Comment On Regulatory Notice 21-19
Chris Early Comment On Regulatory Notice 21-19
Roger Reyes Comment On Regulatory Notice 21-19
Khurram Gohar Comment On Regulatory Notice 21-19
Matthew Davis Comment On Regulatory Notice 21-19
Lisa F. Johnson Comment On Regulatory Notice 21-19
Jeremy LaBorde Comment On Regulatory Notice 21-19
Robert Gnat Comment On Regulatory Notice 21-19
Thomas Beattie Comment On Regulatory Notice 21-19
Va Jay Comment On Regulatory Notice 21-19
Jack Jones Comment On Regulatory Notice 21-19
Kathryn Jorgenson Comment On Regulatory Notice 21-19
Bryan Chalker Comment On Regulatory Notice 21-19
Benjamin Nguyen Comment On Regulatory Notice 21-19
Anonymous-AC Comment On Regulatory Notice 21-19
Katherine Hughes Comment On Regulatory Notice 21-19
John LoMeli Comment On Regulatory Notice 21-19
Donny McGee Comment On Regulatory Notice 21-19
Mo Comment On Regulatory Notice 21-19
Anonymous-LG Comment On Regulatory Notice 21-19
Don Comment On Regulatory Notice 21-19
JJ Gunn Comment On Regulatory Notice 21-19
Katie Harrison Comment On Regulatory Notice 21-19
Marc Austin Faubel Comment On Regulatory Notice 21-19
David Fields Comment On Regulatory Notice 21-19
Troy Comment On Regulatory Notice 21-19
Ciara Davis Comment On Regulatory Notice 21-19
Ashley Hardman Comment On Regulatory Notice 21-19
Malik Comment On Regulatory Notice 21-19
Ian Comment On Regulatory Notice 21-19
Michael A Lewandowski Comment On Regulatory Notice 21-19
Anonymous-B Comment On Regulatory Notice 21-19
Anonymous-O Comment On Regulatory Notice 21-19
TJ Comment On Regulatory Notice 21-19
Skip Gibson Comment On Regulatory Notice 21-19
Shane Olson Comment On Regulatory Notice 21-19
Anonymous-AE Comment On Regulatory Notice 21-19
Chris Comment On Regulatory Notice 21-19
Everett Route Comment On Regulatory Notice 21-19
Luis Marquez Comment On Regulatory Notice 21-19
Zachary Fields Comment On Regulatory Notice 21-19
Ricky Lam Comment On Regulatory Notice 21-19
David Preston Comment On Regulatory Notice 21-19
Josh MacDonald Comment On Regulatory Notice 21-19
Aditi Lembhe Comment On Regulatory Notice 21-19
Lazaro Gonzalez Comment On Regulatory Notice 21-19
Anonymous-H Comment On Regulatory Notice 21-19
Antonio Flores Comment On Regulatory Notice 21-19
Tristan Stickel Comment On Regulatory Notice 21-19
Josh Lind Comment On Regulatory Notice 21-19
Emmanuel Rodriguez Comment On Regulatory Notice 21-19
Jake Heid Comment On Regulatory Notice 21-19
Anonymous-KK Comment On Regulatory Notice 21-19
Anthony Bucci Comment On Regulatory Notice 21-19
Jon Comment On Regulatory Notice 21-19
Albin Comment On Regulatory Notice 21-19
Rob Comment On Regulatory Notice 21-19
Mike R Comment On Regulatory Notice 21-19
Michael Hernandez Comment On Regulatory Notice 21-19
Rafael Figueroa Comment On Regulatory Notice 21-19
Tyler Turner Comment On Regulatory Notice 21-19
Javon Orange Comment On Regulatory Notice 21-19
William Cervera Comment On Regulatory Notice 21-19
Jay Herrin Comment On Regulatory Notice 21-19
S Sanchez Comment On Regulatory Notice 21-19
James Erskine Comment On Regulatory Notice 21-19
Perry Comment On Regulatory Notice 21-19
Brad Comment On Regulatory Notice 21-19
Jeffrey Montero Comment On Regulatory Notice 21-19
Christopher Bishop Comment On Regulatory Notice 21-19
Keith SImon Comment On Regulatory Notice 21-19
Hammond Meuer Comment On Regulatory Notice 21-19
Anonymous-TL Comment On Regulatory Notice 21-19
Darryl Holmes Comment On Regulatory Notice 21-19
Jessica Rodriguez Comment On Regulatory Notice 21-19
Anonymous-R Comment On Regulatory Notice 21-19
Tara Comment On Regulatory Notice 21-19
Randall Comment On Regulatory Notice 21-19
Steven Kinner Comment On Regulatory Notice 21-19
Zachary Carson Comment On Regulatory Notice 21-19
Shawn Williams Comment On Regulatory Notice 21-19
Anthony Conforti Comment On Regulatory Notice 21-19
Courtney More Comment On Regulatory Notice 21-19
Frank Thelen Comment On Regulatory Notice 21-19
Anonymous-DD Comment On Regulatory Notice 21-19
Chris Harden Comment On Regulatory Notice 21-19
Eric Guerra Comment On Regulatory Notice 21-19
Ishmael Williams Comment On Regulatory Notice 21-19
Justin Columbie Comment On Regulatory Notice 21-19
Darlene Turner Comment On Regulatory Notice 21-19
Josh Hurlburt Comment On Regulatory Notice 21-19
Mary Smith Comment On Regulatory Notice 21-19
Anonymous-JJ Comment On Regulatory Notice 21-19
Sherie Johnson Comment On Regulatory Notice 21-19
Paul Murray Comment On Regulatory Notice 21-19
Thomas Hopely Comment On Regulatory Notice 21-19
James Jackson Comment On Regulatory Notice 21-19
Bill Rogakos Comment On Regulatory Notice 21-19
Anonymous-A Comment On Regulatory Notice 21-19
Stephan Davis Comment On Regulatory Notice 21-19
Kim Young Comment On Regulatory Notice 21-19
Peter Smith Comment On Regulatory Notice 21-19
Kenith L Robinson Comment On Regulatory Notice 21-19
James Walker Comment On Regulatory Notice 21-19
John Kim Comment On Regulatory Notice 21-19
Michelle Tierney Comment On Regulatory Notice 21-19
Anonymous-RI Comment On Regulatory Notice 21-19
Ian Rowland Comment On Regulatory Notice 21-19
Reece Curcio Comment On Regulatory Notice 21-19
Anonymous-WD Comment On Regulatory Notice 21-19
Bryan Greer Comment On Regulatory Notice 21-19
Richard Van Hazel Comment On Regulatory Notice 21-19
Amanda Mears Comment On Regulatory Notice 21-19
Justin Pena Comment On Regulatory Notice 21-19
Anonymous-DT Comment On Regulatory Notice 21-19
James Harris Comment On Regulatory Notice 21-19
Grant Oden Comment On Regulatory Notice 21-19
Lance Shealy Comment On Regulatory Notice 21-19
Tory Brake Comment On Regulatory Notice 21-19
Brett Howell Comment On Regulatory Notice 21-19
Ayman Wahed Comment On Regulatory Notice 21-19
Christopher Verryt Comment On Regulatory Notice 21-19
Steven Genovese Comment On Regulatory Notice 21-19
Chad Johnson Comment On Regulatory Notice 21-19
Anonymous-TCB47 Comment On Regulatory Notice 21-19