As a retail investor, I believe all of the proposed changes should be enacted. Transparency is a requirement for our markets to remain fair and free. Gamestop had a short interest of 140% of the float at one point in December 2020/January 2021 which lead to the WallStreetBets short squeeze and subsequent trading restrictions because of systemic risk. If the short interest had been reported on a more frequent basis, this "idiosyncratic" systemic risk would have been more visible and could have been tackled in a different way other than restricting trading. All of the data points in section B should be enacted as soon as possible to provide visibility into the systemic risk in our system and the data should be made public on a daily basis. Giving people the ability to grow their capital is the biggest strength of the US capital markets and we should be encouraging it through transparency and education. I also believe Fail-To-Deliver positions should also be reported daily and examined with much more scrutiny. Fails-to-deliver in modern capital markets is unacceptable. If Amazon took orders from it's customers, kept the money, and didn't deliver anything, there would be a social media storm tomorrow. Anyone who fails to deliver after settlement should be forced to close out all positions, deliver, and pay a fine equal to the amount in cash of the financial instrument at the time the transaction originally occurred. There should be massive disincentives for failing to deliver and shining a light on how many fails to deliver exists is the first step in eliminating the problem. Ryan Bottoms
Ryan Bottoms Comment On Regulatory Notice 21-19
As a retail investor, I believe all of the proposed changes should be enacted. Transparency is a requirement for our markets to remain fair and free. Gamestop had a short interest of 140% of the float at one point in December 2020/January 2021 which lead to the WallStreetBets short squeeze and subsequent trading restrictions because of systemic risk. If the short interest had been reported on a more frequent basis, this "idiosyncratic" systemic risk would have been more visible and could have been tackled in a different way other than restricting trading. All of the data points in section B should be enacted as soon as possible to provide visibility into the systemic risk in our system and the data should be made public on a daily basis. Giving people the ability to grow their capital is the biggest strength of the US capital markets and we should be encouraging it through transparency and education. I also believe Fail-To-Deliver positions should also be reported daily and examined with much more scrutiny. Fails-to-deliver in modern capital markets is unacceptable. If Amazon took orders from it's customers, kept the money, and didn't deliver anything, there would be a social media storm tomorrow. Anyone who fails to deliver after settlement should be forced to close out all positions, deliver, and pay a fine equal to the amount in cash of the financial instrument at the time the transaction originally occurred. There should be massive disincentives for failing to deliver and shining a light on how many fails to deliver exists is the first step in eliminating the problem. Ryan Bottoms