William Johnson Comment On Regulatory Notice 21-19

FINRA 21-19 is a long overdue; the US has systemic risk developed under the regulatory authority of FINRA's outdated SI reporting policy. While many of the policies mentioned in Regulatory Notice 21-19 address exploitable and ineffective reporting, they also leave gaps/loopholes that could compromise its purpose. The stability of the US markets and the confidence of its global investing participants depend on regulation changes that require SI reporting to be effective in every possible 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. The world is watching. We need and require healthy, fair, and transparent markets. Respectfully, William Johnson