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
Heinrich Fan Comment On Regulatory Notice 21-19
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