Greetings to the person reading this message and thank you for the consideration. FINRA 21-19 is a long overdue change. It is clear that perceptions of the integrity of the United States market is at great risk, in large part due to FINRA's outdated short interest reporting policy. While many of the policies mentioned in Regulatory Notice 21-19 address the general breadth of exploitable and ineffective reporting, they also leave significant specific gaps that could compromise the entirety of 21-19's purpose. It is critical for the restoration of both the stability of the US markets and the confidence of the investors within it that any and all regulation changes regarding short interest reporting be effective in every known circumstance where effective short positions, synthetic or not, can go unaccounted for for any length of time greater than any other short position reporting 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 economy. We are in the Age of Information and globally retail investors are able to communicate in a near instant. The advantages held by large private institutions gained through ethically questionable means are being put in a spotlight under a microscope. Awareness of and participation in the markets is on the rise and the decentralized nature of communication between investors necessitates a more agile and accommodating regulatory body. A regulatory body which is for the people by the people. My regards.
Topp Comment On Regulatory Notice 21-19
Greetings to the person reading this message and thank you for the consideration. FINRA 21-19 is a long overdue change. It is clear that perceptions of the integrity of the United States market is at great risk, in large part due to FINRA's outdated short interest reporting policy. While many of the policies mentioned in Regulatory Notice 21-19 address the general breadth of exploitable and ineffective reporting, they also leave significant specific gaps that could compromise the entirety of 21-19's purpose. It is critical for the restoration of both the stability of the US markets and the confidence of the investors within it that any and all regulation changes regarding short interest reporting be effective in every known circumstance where effective short positions, synthetic or not, can go unaccounted for for any length of time greater than any other short position reporting 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 economy. We are in the Age of Information and globally retail investors are able to communicate in a near instant. The advantages held by large private institutions gained through ethically questionable means are being put in a spotlight under a microscope. Awareness of and participation in the markets is on the rise and the decentralized nature of communication between investors necessitates a more agile and accommodating regulatory body. A regulatory body which is for the people by the people. My regards.