1/ Synthetic short positions should be included in short interest reports. 2/ REGSHO- information of allocations of FTD's should definately be updated. daily report of FTD's should be mandatory.3/Publication of short interest for Exchange listed Equity securities to include both OTC & Exchange should also be implemented. 4/ Rule 4560-Loan obligations regarding short position closures. Please change this to include the shares borrowed through an arranged finance deal. 5/ Reporting of short interest positions would of course be more beneficial if daily.6/ Daily allocation of FTD positions again seems obvious to help Finra conduct investigations. 6/ Dark pool trades should have a minimum number of shares of at least a number most people would call large. I'd say 50000 shares minimum. It was never meant to be a parking lot for small blocks of a few shares! 7/ Finally, fines imposed for breaking your rules or SEC rules need to be much higher. Thank you
Jim Littler Comment On Regulatory Notice 21-19
1/ Synthetic short positions should be included in short interest reports. 2/ REGSHO- information of allocations of FTD's should definately be updated. daily report of FTD's should be mandatory.3/Publication of short interest for Exchange listed Equity securities to include both OTC & Exchange should also be implemented. 4/ Rule 4560-Loan obligations regarding short position closures. Please change this to include the shares borrowed through an arranged finance deal. 5/ Reporting of short interest positions would of course be more beneficial if daily.6/ Daily allocation of FTD positions again seems obvious to help Finra conduct investigations. 6/ Dark pool trades should have a minimum number of shares of at least a number most people would call large. I'd say 50000 shares minimum. It was never meant to be a parking lot for small blocks of a few shares! 7/ Finally, fines imposed for breaking your rules or SEC rules need to be much higher. Thank you