FINRA 21-19 is a long overdue change. It is clear that there is a systematic flaw in the United States market that if continued, will lead to disaster. A large part of this issue is the outdated short interest reporting policy. While many of the policies mentioned in Regulatory Notice 21-19 address the general breadth of exploitable and ineffective reporting, they also leave significant specific gaps that could compromise the entirety of 21-19’s purpose. In order for investors to invest in US markets with confidence all regulation changes regarding short interest reporting must 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 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.
Gabriel Mulero Comment On Regulatory Notice 21-19
FINRA 21-19 is a long overdue change. It is clear that there is a systematic flaw in the United States market that if continued, will lead to disaster. A large part of this issue is the outdated short interest reporting policy. While many of the policies mentioned in Regulatory Notice 21-19 address the general breadth of exploitable and ineffective reporting, they also leave significant specific gaps that could compromise the entirety of 21-19’s purpose. In order for investors to invest in US markets with confidence all regulation changes regarding short interest reporting must 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 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.