Nunya Comment On Regulatory Notice 21-19
Here are some examples on how the system could be improved: 1. Reduce the reporting period to weekly (or preferably daily) from biweekly. 2. Require that exchanges report failures to deliver and naked shorts alongside covered shorts. 3. Reduce the holding period for reported days from 4 days to 2 or fewer. 4. Document and release the identities of funds that have open short positions and their sizes. This would operate similarly to the way longs and options are currently reported. 5. Regularly audit the reported positions to ensure the self reporting is accurate and fine (or penalize) entities that misreport. This would include going deep to ensure that no shorts are being hidden in long options contracts, or mislabeled as long positions.