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Darin Harper Comment On Regulatory Notice 21-19

Darin Harper
Real Estate

Thank you for asking for comments. I am a fairly new investor (got more serious in January). I love numbers and reports so you can imagine my frustration with all the different results at the end of each day regarding short interest. Fintel would say one thing and Ortex another, etc. I also follow litigation news as well and had a suspicion confirmed when a firm was accused of marking shorts as longs. I finally started keeping charts on short interest for specifically AMC in a spreadsheet based off of your daily short report. (Am frustrated I can't seem to download the monthly) I know your report only covers market hours but there is still a considerable different in the volume of your "consolidated" report and the actual volume. I can only imagine that the difference is the dark pool volume (because AMC is being traded at 60% dark currently). This does not give a complete picture of a stock's real short interest. I also don't see how/why market makers are given large passes on short exemption. We need a system that is very clear about what the current short interest is at any given time for a particular stock including the sources from each. In summary, more auditing (especially on stocks that are getting exemptions or are highly shorted or on the threshold report) to ensure market makers are actually marking shorts as shorts and aren't taking exemptions when they shouldn't) and clearer, more transparent, timely reporting with the same information that a broker would have at hand including clear division of where each source is from - B,N,Q Dark Pool, etc. (also short volume from PM and AH from previous day. I am still learning but love to read reports daily. Thanks Again and good luck with the new system Darin Harper