The confidence in the US market is waning and will collapse in time. For too long FINRA's out-dated short interest reporting policy has allowed malicious activities to continue with little to no oversight in the form of abusive and extraordinary over-leveraging of short positions. Many of the policies mentioned in Regulatory Notice 21-19 address the short interest ineffective reporting, yet, they also leave significant holes that compromise the entirety of 21-19's purpose, almost as if they were left this way. When FINRA requests that, "commenters provide empirical data or other factual support for their comments whenever possible" I ask why? That is the not job of citizens. That is the job of the employees at FINRA who are being to paid work there; or is it a call to the ineptitude of this regulatory body. It is imperative that the restoration of stability and confidence of the investors that use the US markets that any regulations changes regarding short interest reporting be effective in every known application of where effective short positions, synthetic or not, can go unaccounted for, for any length of time greater than any other short position reporting deadline. Lastly, operational costs for market members to accommodate these standards cannot be reasonably compared to the cost of a compromised market with systematic risk on the verge of collapse, daily, or the loss of investor confidence and participation in the US economy.
Anonymous-NB Comment On Regulatory Notice 21-19
The confidence in the US market is waning and will collapse in time. For too long FINRA's out-dated short interest reporting policy has allowed malicious activities to continue with little to no oversight in the form of abusive and extraordinary over-leveraging of short positions. Many of the policies mentioned in Regulatory Notice 21-19 address the short interest ineffective reporting, yet, they also leave significant holes that compromise the entirety of 21-19's purpose, almost as if they were left this way. When FINRA requests that, "commenters provide empirical data or other factual support for their comments whenever possible" I ask why? That is the not job of citizens. That is the job of the employees at FINRA who are being to paid work there; or is it a call to the ineptitude of this regulatory body. It is imperative that the restoration of stability and confidence of the investors that use the US markets that any regulations changes regarding short interest reporting be effective in every known application of where effective short positions, synthetic or not, can go unaccounted for, for any length of time greater than any other short position reporting deadline. Lastly, operational costs for market members to accommodate these standards cannot be reasonably compared to the cost of a compromised market with systematic risk on the verge of collapse, daily, or the loss of investor confidence and participation in the US economy.