Dear Sir/Madam:
Leveraged and inverse funds are a vital part of helping me to hedge my portfolio and avoiding constant trading. I use these tools to short the S&P 500 or other indexes when they have become frothy (in my view). These products reduce the volatility and allow me to stay in core positions longer. I use them as short-term hedges and the risks of staying in them too long
Limiting the ability of the common stock holder to use leveraged stocks leave the market free for only the privileged few. Wrong doing and unjust.
If we can buy crypto and penny stocks, we should certainly be able to buy leverage stocks as well, if we so choose.
Short positions should be reported daily. FTD data reported daily. No more hiding behind walls of lag time. Reporting needs to be mandatory and verifiable, not merely self-reported. Punishments for non-compliance or falsification need to be much more severe and timely. Short reporting needs to also include the level of options sales that are naked. Naked Options produce synthetic shares and
FINRA 21-19 will help to restore some of my confidence in the US financial markets. I say some because It is clear that the integrity of the United States market has been strained to the edge of disaster, in large part due to systemic risk developed under the regulatory authority of FINRA's outdated short interest reporting policy. Healthy markets benefit everyone in the long term. Given the
Thank you for your time. Currently as it stands, there is too little information in true short positions. With a market makers ability to create synthetic shares for “liquidity”, at some point the true positions need to be accounted for. If a bank, a market maker, and or other parties can hide positions through layered securities like CDOs or swaps, there is no benefit to the market, only the
I am encouraged that you are considering changes on the subjects of Short Interest Position Reporting Enhancements and Other Changes Related to Short Sale Reporting. These changes are will open the way to fair market operations. In the current environment the technology and information for market operations is far superior compared to what is available to regulators and ultimately the public.
Publication Date: February 23, 2023
Interpretations are marked in blue background beneath the rule text to which they relate.
15c3-1g Conditions for ultimate holding companies of certain brokers or dealers (Appendix G to 17 CFR 240.15c3-1).
As a condition for a broker or dealer to compute certain of its deductions to capital in accordance with § 240.15c3-1e, pursuant to its undertaking, the
I for one am in favor of the enhanced reporting requires. An efficient market can only exist when accurate information is available to make informed decisions. As there is ample evidence of past and present naked shorting despite restrictions against it, requiring proper disclosures of large short positions, along with sufficient penalties to ensure accurate reporting is critical to identify the
General’s speaking, the more reporting, the better. Especially when it comes to short interest as well as synthetic short positions. As a day/swing trader, given how quickly the markets move and their volatility, weekly reporting doesn’t help me because I need to operate on the most up to date information possible. So daily reporting would be the only thing worth it to me. Thanks for doing this
