FINRA 21-19 is long overdue. Outdated short interest reporting policy has resulted in systemic risk to the integrity of US markets. While many of the policies mentioned in regulatory notice 21-19 generals address exploitable and ineffective reporting, they also have significant loop holes that would defeat the entire purpose of 21-19. It is critical for the restoration of stability in both the US markets and confidence of investors within it that any and all regulation changes regarding short interest reporting be effective in every known circumstance—where effective short positions, synthetic or not, can go unaccounted for for any length of time greater than any other short position reporting deadline . Additionally the cost of operations necessary for applicable market members to accommodate these standards can’t be reasonably compared to the cost of a compromised market with systemic risk or the loss of investor confidence and participation in the US economy.
Anonymous-G Comment On Regulatory Notice 21-19
FINRA 21-19 is long overdue. Outdated short interest reporting policy has resulted in systemic risk to the integrity of US markets. While many of the policies mentioned in regulatory notice 21-19 generals address exploitable and ineffective reporting, they also have significant loop holes that would defeat the entire purpose of 21-19. It is critical for the restoration of stability in both the US markets and confidence of investors within it that any and all regulation changes regarding short interest reporting be effective in every known circumstance—where effective short positions, synthetic or not, can go unaccounted for for any length of time greater than any other short position reporting deadline . Additionally the cost of operations necessary for applicable market members to accommodate these standards can’t be reasonably compared to the cost of a compromised market with systemic risk or the loss of investor confidence and participation in the US economy.