Our country and history has been brought about by change. Change that may have seemed difficult at the start, may have been viewed negatively, avoided, or even resisted, but eventually led to the greater good for all. This is no different. FINRA 21-19 is a change that needs to happen for the greater good of all. It’s a change that is long overdue and needs to be expedited into action. Where there are cracks for things to slip through, loopholes for entities and people to use and abuse, these things will happen. This has aided shady tactics for corporations with the current short interest policy supported by FINRA. All of which further damage the views of Americans and other countries of the United States market. This deteriorates the faith and trust as more deceit and trickery comes to light. FINRA 21-19 does help to address some concerns regarding the exploitable and ineffective reporting of short interest, but not to the degree necessary to ensure 100% coverage and transparency. This in and of itself undermines the purpose of 21-19, compromising its integrity and strength. It is beyond critical for the restoration of the stability of the United States market, and the faith and trust of all investors within it, that any and all regulation changes regarding short interest reporting be completely and totally effective in every known and possible circumstances where all types of short positions, synthetic (fake, phantom, etc.) or not, can not be allowed to go unaccounted for or reported, for any length of time greater than any other short position reporting deadline. Nor can they be allowed to be shifted in such a way that it skews or allows for false or misleading reporting to mitigate or protect losses of those engaged in fraudulent activities with any security within the stock market. In addition to this, the cost of operations necessary for all 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 economy of the United States.
Dustin Comment On Regulatory Notice 21-19
Our country and history has been brought about by change. Change that may have seemed difficult at the start, may have been viewed negatively, avoided, or even resisted, but eventually led to the greater good for all. This is no different. FINRA 21-19 is a change that needs to happen for the greater good of all. It’s a change that is long overdue and needs to be expedited into action. Where there are cracks for things to slip through, loopholes for entities and people to use and abuse, these things will happen. This has aided shady tactics for corporations with the current short interest policy supported by FINRA. All of which further damage the views of Americans and other countries of the United States market. This deteriorates the faith and trust as more deceit and trickery comes to light. FINRA 21-19 does help to address some concerns regarding the exploitable and ineffective reporting of short interest, but not to the degree necessary to ensure 100% coverage and transparency. This in and of itself undermines the purpose of 21-19, compromising its integrity and strength. It is beyond critical for the restoration of the stability of the United States market, and the faith and trust of all investors within it, that any and all regulation changes regarding short interest reporting be completely and totally effective in every known and possible circumstances where all types of short positions, synthetic (fake, phantom, etc.) or not, can not be allowed to go unaccounted for or reported, for any length of time greater than any other short position reporting deadline. Nor can they be allowed to be shifted in such a way that it skews or allows for false or misleading reporting to mitigate or protect losses of those engaged in fraudulent activities with any security within the stock market. In addition to this, the cost of operations necessary for all 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 economy of the United States.