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Heinrich Fan Comment On Regulatory Notice 21-19

Heinrich Fan

To whom it may concern, I am writing in support of the proposed changes applied in Reg. Notice 21-19. Particularly as an individual investor in the US financial markets, I am strongly in support of daily aggregation of short interest reporting. I strongly support increased granularity to the account level position reporting. I am adamantly in support of increasing comprehensive synthetic short interest reporting (I would suggest a clause for these tactics to be continually evaluated and updated for, i.e. other methods of creating synthetic positions) due to, for example a married put strategy as described in the Reg. Notice. I strongly support reporting of loan obligations and their inclusion in SI calculation. I am strongly in support of third party reporting of TSO and public float information to be publically available. As mentioned before, I am strongly in support of increased frequency of reporting requirements to days from semi-monthly. I am adamantly in support of Section D. of the Reg. Notice regarding fails to deliver. This item will likely be the most fiercely debated. I believe increased allocation reporting for FTDs is critical to establishing this regulations intended significance. I feel it is particularly important to defend the proposed requirements for DAILY reporting of trade, allocation, and close out dates as well as the applicable close out obligation. I am encouraged by this new regulatory regime and look forward to its support and enforcement by your agency. Thank you very much for your time. Heinrich Fan