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Jay Herrin Comment On Regulatory Notice 21-19

Jay Herrin

I appreciate the opportunity to submit comments on Short Interest Reporting. I am not against short selling, and as a retail investor I have made some very profitable trades over the years on the short side. However, I was always required to locate the shares, request to borrow and confirm they were received before I could enter the position. I am concerned that the current rules are not being followed by the institutional firms, and they are not being enforced by governing bodies. If the reporting requirements were more frequent I think this would help. Daily reporting should be required and would help to expose the firms that are taking advantage of the system by creating shares that do not exist and shorting them into the market. It seems that naked shorts or synthetic shorts are an everyday common practice even though it is illegal. The rules are not being enforced. I do not understand why this is allowed to happen when everyone knows it is happening. If you do some basic math it is obvious that this is happening to 100s if not 1000s of companies. I see it every day. In summary, I would love to see current market rules enforced , and short position reporting should be required at least once a day. FTDs? Never mind, I could go on but I won't. Again, thank you for the opportunity to submit comments on this matter. Sincerely, Concerned investor who is about to loose faith in our financial oversight system.