Amy W Comment On Regulatory Notice 21-19
Hello, I wholeheartedly support FINRA's step toward a slightly more transparent system. FINRA requests comment on whether FINRA should publish on the FINRA website short interest data for all equity securities (listed and unlisted). • Yes, absolutely all short interest data should be published. FINRA requests comment on whether the potential short interest enhancements discussed above would be equally beneficial for both OTC equity securities and exchange-listed equity securities. • Having spent the past week attempting to garner good data for short interest and finding only incorrect information, yes it would be massively beneficial to actually have this information available. Are there any aspects of the proposal that should apply differently to exchange-listed equity securities or OTC equity securities? If so, please explain. • No, this should apply equally regardless of what the underlying is. • 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? No. Who actually cares about OTC securities? All of the fraud and naked short selling is taking place on exchange listed securities. Predominantly on NYSE listed ones. This needs to the curtain pulling back, and an effective daily reporting structure put in place. Are there any expected potential competitive effects associated with this change? • Shedding light on short selling behavior and reducing the reporting period from every 15 days to daily would make it very hard for market participants to hide their fraudulent activities. I would further ask that synthetic long positions generated through reverse conversion of options be tracked as well, as I believe you will find a direct relationship between that number increasing, and FTDs decreasing.