Regulatory Notice 21-19 addresses the general breadth of exploitable and ineffective reporting, they also leave significant gaps compromising the entirety of 21-19’s purpose. It is critical for the restoration of both the stability of the US markets and confidence of investors with in it that all regulation changes regarding short interest reporting be effective in every known circumstance where short positions, synthetic or not, can go unaccounted for with any length of time greater than any other short position deadline. Additionally the cost of operations necessary for applicable market members to accommodate these standards cannot be reasonably compared to the cost of a compromised market with systemic risk or the loss of investor confidence and participation in the US market.
Stephanie P Comment On Regulatory Notice 21-19
Regulatory Notice 21-19 addresses the general breadth of exploitable and ineffective reporting, they also leave significant gaps compromising the entirety of 21-19’s purpose. It is critical for the restoration of both the stability of the US markets and confidence of investors with in it that all regulation changes regarding short interest reporting be effective in every known circumstance where short positions, synthetic or not, can go unaccounted for with any length of time greater than any other short position deadline. Additionally the cost of operations necessary for applicable market members to accommodate these standards cannot be reasonably compared to the cost of a compromised market with systemic risk or the loss of investor confidence and participation in the US market.