Finra Question 1: What implementation period would be appropriate to provide members with sufficient time to make the systems changes necessary to comply with this requirement? My Answer: Change needs to happen as soon as possible Finra Question 2: FINRA is considering whether daily or weekly short interest position reporting would be preferable. What are commenters’ views on the preferred frequency of short interest position reporting? My Answer: Daily is preferable Finra Question 3: Are there any other short sale-related changes not discussed above that commenters recommend? Please explain My Answer: * Eliminate dark pools * Fines should be greater than the profit hedge made from the illegal activity * Jail time is needed for market manipulation. * Short positions should be forcibly closed out if illegal market manipulation is found and trading rights of those involved should be revoked. * Shorting taking place in the dark pool needs to be disclosed to the public. If an institution buys shares in the dark pool and then dumps (sells) those same shares on the public exchanges to tank the price, this should have to be reported. * Fail to Delivers should be reported to the public as well as Finra. * Short interest should not be self reported. There should be a system in place where short interest is automatically reported. Perhaps a computer system could be designed that tracks when a security is shorted and covered and automatically reports this back to Finra. * There should be audits done to check for shorts hidden in options.
Song Comment On Regulatory Notice 21-19
Finra Question 1: What implementation period would be appropriate to provide members with sufficient time to make the systems changes necessary to comply with this requirement? My Answer: Change needs to happen as soon as possible Finra Question 2: FINRA is considering whether daily or weekly short interest position reporting would be preferable. What are commenters’ views on the preferred frequency of short interest position reporting? My Answer: Daily is preferable Finra Question 3: Are there any other short sale-related changes not discussed above that commenters recommend? Please explain My Answer: * Eliminate dark pools * Fines should be greater than the profit hedge made from the illegal activity * Jail time is needed for market manipulation. * Short positions should be forcibly closed out if illegal market manipulation is found and trading rights of those involved should be revoked. * Shorting taking place in the dark pool needs to be disclosed to the public. If an institution buys shares in the dark pool and then dumps (sells) those same shares on the public exchanges to tank the price, this should have to be reported. * Fail to Delivers should be reported to the public as well as Finra. * Short interest should not be self reported. There should be a system in place where short interest is automatically reported. Perhaps a computer system could be designed that tracks when a security is shorted and covered and automatically reports this back to Finra. * There should be audits done to check for shorts hidden in options.