I'm a retail investor, of the style that invests my meager retirement in ETFs and other low-risk vehicles. I've recently become more interested in managing my own IRA and such, in part due to the fervor surrounding GME and other tremendously short sold stocks. This interest let me to reading extensively about short interest, reporting, FTDs, and the options techniques used to "hide" short positions from the lit market. At one point, during the January runup initally with GME, for a short while GME was >100% short. Such a thing should not be possible, at is suggests more shares are being traded or borrowed than actually exist. I Understand that several of the provisions proposed in 21-19 would tighten up reporting requirements for FTD and short positions, and include the reporting of so-called "Synthetic" short positions. As an investor, and small startup company owner who hopes one day to IPO my growing startup, the very idea that "Synthetic" short positions are allowed to exist in such a way that could collapse entire companies seems opposite to the American Experience and "free market" concepts that are the bedrock of our financial system. Now that I'm 10 months into following FTD and SI% for various investments I hold, I find the need for increased reporting and regulation (and of closing some of the most egregious loopholes) to be in the best interest of our economy. Notably, this includes the frequency of data updates: 2 week reporting interval seems insane for a facility that is ostensibly monitoring millisecond-timed HFT algo-based trading systems. Additionally, the very notion of "synthetic" short positions, whereby Market Makers appear to use their abilities to leverage PFOF data from "free" brokerages to synthetically derive positions to benefit from retail's slower data seems to be immoral at best, and a fundamental threat to Free Markets at worse. There are many people more skilled in the area of financial markets commenting here than I am, but as one of the growing number of retail investors taking an active interest of managing our finances directly, I'd like FINRA to have the tools required to perform their tasks as a regulation authority for broker-dealers.
Greg Linder Comment On Regulatory Notice 21-19
I'm a retail investor, of the style that invests my meager retirement in ETFs and other low-risk vehicles. I've recently become more interested in managing my own IRA and such, in part due to the fervor surrounding GME and other tremendously short sold stocks. This interest let me to reading extensively about short interest, reporting, FTDs, and the options techniques used to "hide" short positions from the lit market. At one point, during the January runup initally with GME, for a short while GME was >100% short. Such a thing should not be possible, at is suggests more shares are being traded or borrowed than actually exist. I Understand that several of the provisions proposed in 21-19 would tighten up reporting requirements for FTD and short positions, and include the reporting of so-called "Synthetic" short positions. As an investor, and small startup company owner who hopes one day to IPO my growing startup, the very idea that "Synthetic" short positions are allowed to exist in such a way that could collapse entire companies seems opposite to the American Experience and "free market" concepts that are the bedrock of our financial system. Now that I'm 10 months into following FTD and SI% for various investments I hold, I find the need for increased reporting and regulation (and of closing some of the most egregious loopholes) to be in the best interest of our economy. Notably, this includes the frequency of data updates: 2 week reporting interval seems insane for a facility that is ostensibly monitoring millisecond-timed HFT algo-based trading systems. Additionally, the very notion of "synthetic" short positions, whereby Market Makers appear to use their abilities to leverage PFOF data from "free" brokerages to synthetically derive positions to benefit from retail's slower data seems to be immoral at best, and a fundamental threat to Free Markets at worse. There are many people more skilled in the area of financial markets commenting here than I am, but as one of the growing number of retail investors taking an active interest of managing our finances directly, I'd like FINRA to have the tools required to perform their tasks as a regulation authority for broker-dealers.