FINRA 21-19 is something that our "free and fair" markets desperately need. For too long, retail investors like myself have been kept in the dark. It has become more clear than ever that our markets are teetering on a sword's edge due to a lack of transparency and accountability. - Account-level Position Information: Alternatively, FINRA is considering requiring firms to report (for regulatory purposes only; not to be disseminated publicly) short interest position information with more granularity by reporting at the account level for all equity securities. This should have already been in place years ago. - Synthetic Short Positions: In addition, FINRA is considering requiring firms to reflect synthetic short positions in short interest reports. The fact that this has been omitted from reporting leads to the outrageous levels of leverage (e.g. Archegos) that we are currently seeing. This is essential reporting. - Total Shares Outstanding (TSO) and Public Float: FINRA also is considering including in FINRA-disseminated short interest data, where available, the TSO and public float for securities. I encourage FINRA to obtain and release this information to the public. Retail investors deserve access to the same information as large investment firms. Every measure in 21-19 is a step in the right direction. While I would like to see even more transparency for the retail investor, 21-19 is at least a good start. I implore FINRA to enact these measures for the betterment of our markets and to address the issues that retail investors are extremely concerned about.
Scott Comment On Regulatory Notice 21-19
FINRA 21-19 is something that our "free and fair" markets desperately need. For too long, retail investors like myself have been kept in the dark. It has become more clear than ever that our markets are teetering on a sword's edge due to a lack of transparency and accountability. - Account-level Position Information: Alternatively, FINRA is considering requiring firms to report (for regulatory purposes only; not to be disseminated publicly) short interest position information with more granularity by reporting at the account level for all equity securities. This should have already been in place years ago. - Synthetic Short Positions: In addition, FINRA is considering requiring firms to reflect synthetic short positions in short interest reports. The fact that this has been omitted from reporting leads to the outrageous levels of leverage (e.g. Archegos) that we are currently seeing. This is essential reporting. - Total Shares Outstanding (TSO) and Public Float: FINRA also is considering including in FINRA-disseminated short interest data, where available, the TSO and public float for securities. I encourage FINRA to obtain and release this information to the public. Retail investors deserve access to the same information as large investment firms. Every measure in 21-19 is a step in the right direction. While I would like to see even more transparency for the retail investor, 21-19 is at least a good start. I implore FINRA to enact these measures for the betterment of our markets and to address the issues that retail investors are extremely concerned about.