" Publication of Short Interest for Exchange-listed Equity Securities" Why are firms are currently allowed to hold any unreported open short positions? In the OTC market, one firm's large short position could potentially destroy a company. " Content of Short Interest Data" The more data points you collect and publish, the better. A free and fair market means transparency for everybody. There's no reason firms should have access to every dimension of information, while they themselves remaining vague. The fact they are allowed to withhold ANY information from regulatory agencies is scary, let alone fundamental data regarding their positions. "Proprietary and Customer Account Categorization" In favor. "Account-level Position Information" It seems essential to me that FINRA should know the identity of entities who open large short positions. Firms can create as many short positions as they want and remain entirely anonymous to their overseers (FINRA)? "Synthetic Short Positions" Regulators should be able to interpret data and assess how many synthetic shorts have been created by market participant activity. This issue poses a threat to the market. It's illegal to counterfeit securities so why is naked short selling allowed? The current rules allow for naked short selling and almost condone this act by imposing easily paid and forgotten fines by those that regularly take advantage. "Loan Obligations Resulting From Arranged Financing:" It should not be possible to close shorts by borrowing shares because what they are actually doing is closing shorts by opening shorts, and they don't even have to report it to FINRA. That is ripe for abuse. "Total Shares Outstanding (TSO) and Public Float:" Allow FINRA to disseminate short interest data. Everybody should have access to it, if what we want is a fair market. "Threshold Security Field" I agree with FINRA that a security's status as a threshold security is useful to investors, and that it should be disseminated accurately and transparently. " Frequency and Timing of Short Interest Position Reporting and Data Dissemination" Short position data should be required to be updated hourly and should be easy to comply with unless abuse is occurring. Regulation needs to be directed towards immediate reporting and dissemination of short-interest data. “Information on Allocations of Fail-to-Deliver Positions” In favor. Transferring FTDs between firms in order to obfuscate their existence is incredibly deceptive behavior; not having to report those movements at all is unacceptable... The systemic risks posed by short sellers and their lack of oversight are well beyond what any fair and just market would allow for. Repeatedly failing-to-deliver shares, and systematically juggling those FTDs around and trying to hide them cannot be interpreted as anything except collusion & fraud. "Publication of Short Interest for Exchange-listed Equity Securities" We need transparency in order to have a free market. I am in favor of FINRA consolidating and disseminating short interest data both for exchange-listed and OTC securities. Proper reform and regulation of our markets is mandatory if we are to have a market that future generations will trust and want to participate in. Failure to fix our market in a meaningful way may be an existential threat to the United States' preeminent position in the global economy. The rule changes proposed by Regulatory Notice 21-19 are critically important for the health of our markets. As an individual investor who is quickly losing confidence in the ability and/or willingness of regulatory agencies to perform their primary function, I feel this notice deserves unanimous support from all regulators and market participants, and deterministic action should be taken by FINRA to codify all of the rule changes proposed by 21-19.
Hope Zantes Comment On Regulatory Notice 21-19
" Publication of Short Interest for Exchange-listed Equity Securities" Why are firms are currently allowed to hold any unreported open short positions? In the OTC market, one firm's large short position could potentially destroy a company. " Content of Short Interest Data" The more data points you collect and publish, the better. A free and fair market means transparency for everybody. There's no reason firms should have access to every dimension of information, while they themselves remaining vague. The fact they are allowed to withhold ANY information from regulatory agencies is scary, let alone fundamental data regarding their positions. "Proprietary and Customer Account Categorization" In favor. "Account-level Position Information" It seems essential to me that FINRA should know the identity of entities who open large short positions. Firms can create as many short positions as they want and remain entirely anonymous to their overseers (FINRA)? "Synthetic Short Positions" Regulators should be able to interpret data and assess how many synthetic shorts have been created by market participant activity. This issue poses a threat to the market. It's illegal to counterfeit securities so why is naked short selling allowed? The current rules allow for naked short selling and almost condone this act by imposing easily paid and forgotten fines by those that regularly take advantage. "Loan Obligations Resulting From Arranged Financing:" It should not be possible to close shorts by borrowing shares because what they are actually doing is closing shorts by opening shorts, and they don't even have to report it to FINRA. That is ripe for abuse. "Total Shares Outstanding (TSO) and Public Float:" Allow FINRA to disseminate short interest data. Everybody should have access to it, if what we want is a fair market. "Threshold Security Field" I agree with FINRA that a security's status as a threshold security is useful to investors, and that it should be disseminated accurately and transparently. " Frequency and Timing of Short Interest Position Reporting and Data Dissemination" Short position data should be required to be updated hourly and should be easy to comply with unless abuse is occurring. Regulation needs to be directed towards immediate reporting and dissemination of short-interest data. “Information on Allocations of Fail-to-Deliver Positions” In favor. Transferring FTDs between firms in order to obfuscate their existence is incredibly deceptive behavior; not having to report those movements at all is unacceptable... The systemic risks posed by short sellers and their lack of oversight are well beyond what any fair and just market would allow for. Repeatedly failing-to-deliver shares, and systematically juggling those FTDs around and trying to hide them cannot be interpreted as anything except collusion & fraud. "Publication of Short Interest for Exchange-listed Equity Securities" We need transparency in order to have a free market. I am in favor of FINRA consolidating and disseminating short interest data both for exchange-listed and OTC securities. Proper reform and regulation of our markets is mandatory if we are to have a market that future generations will trust and want to participate in. Failure to fix our market in a meaningful way may be an existential threat to the United States' preeminent position in the global economy. The rule changes proposed by Regulatory Notice 21-19 are critically important for the health of our markets. As an individual investor who is quickly losing confidence in the ability and/or willingness of regulatory agencies to perform their primary function, I feel this notice deserves unanimous support from all regulators and market participants, and deterministic action should be taken by FINRA to codify all of the rule changes proposed by 21-19.