I am commenting in regards to particular aspects of FINRA 21-19, which I do support and believe should have been enacted long ago. Undoubtedly, the public’s faith in the United States market has been diminishing following the many preventable financial crises that have occurred in the past. The ongoing state of the market from retail investors points of view, frankly appears broken and has failed to manage systemic risk in the interest of the public, rather FINRA’s ridiculous short interest reporting policy has only benefited everyone but the average American. While some of the policies mentioned in Regulatory Notice 21-19 do address the broad subject of exploitable/ineffective/unfair reporting, it also leaves significant particular loopholes that could potentially by used to undermine the importance of 21-19's purpose. The unique circumstances that have occurred over the past several years has inexplicably crushed the faith of the public in America’s markets. While the majority of Americans already believe Wall Street is corrupt, without a doubt the public now is one step away from not only leaving the US markets, but losing faith the country all together. Any changes or amendments to short interest reporting must actually make a difference and hold those accountable, otherwise if effective short positions, synthetic or not, continue to go unaccounted for for any length of time greater than any other short position reporting deadline, the US market will effectively have become the laughing stock of the world. Additionally, the cost of operations necessary for applicable market members to accommodate these standards cannot 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. Ra.
Anonymous-MM Comment On Regulatory Notice 21-19
I am commenting in regards to particular aspects of FINRA 21-19, which I do support and believe should have been enacted long ago. Undoubtedly, the public’s faith in the United States market has been diminishing following the many preventable financial crises that have occurred in the past. The ongoing state of the market from retail investors points of view, frankly appears broken and has failed to manage systemic risk in the interest of the public, rather FINRA’s ridiculous short interest reporting policy has only benefited everyone but the average American. While some of the policies mentioned in Regulatory Notice 21-19 do address the broad subject of exploitable/ineffective/unfair reporting, it also leaves significant particular loopholes that could potentially by used to undermine the importance of 21-19's purpose. The unique circumstances that have occurred over the past several years has inexplicably crushed the faith of the public in America’s markets. While the majority of Americans already believe Wall Street is corrupt, without a doubt the public now is one step away from not only leaving the US markets, but losing faith the country all together. Any changes or amendments to short interest reporting must actually make a difference and hold those accountable, otherwise if effective short positions, synthetic or not, continue to go unaccounted for for any length of time greater than any other short position reporting deadline, the US market will effectively have become the laughing stock of the world. Additionally, the cost of operations necessary for applicable market members to accommodate these standards cannot 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. Ra.