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Joseph Leos Comment On Regulatory Notice 21-19

Joseph Leos

B. Content of Short Interest Data - The addition of reporting short interest by categories to give a more accurate picture of which entities hold what positions is great for accountability and keeping an open fair market. - Yes. Any short/long position should be reported the same. Synthetic short positions have a history of being used to conceal a form of market manipulation due to its ability to bypass current reporting requirements. - Threshold securites should be given the decency of being shown who is shorting or failing to deliver the stock. Why are we victimizing a company getting bet against instead of the institutions or people putting them on that list.