I would like to see the following changes: Require that firms include synthetic short positions On the FINRA website- Make available short interest data for all equity securities (listed and unlisted). Short interest and short sale volume to be disclosed at a daily frequency Require firms to report short interest positions at the account level Require a report of daily allocations of fail-to-
Anyone who has looked at the derivates market for $AMC and $GME knows that short interest is being aritfically brought down by the use of these options strategies. If the short interest was really as low as being reported by FINRA and others, we would not have outrageous borrow rates and a continuing avalanche of FTD's. When will we have transparency in our financial markets? "Synthetic
FINRA Requests Comment on a Proposal to Identify OTC Equity Trades Reported More Than Two Seconds After Execution as “Out of Sequence” and Not Last Sale Eligible
FINRA is here to help keep investors and their investments safe. To ensure this protection, we enact rules and publish guidance for securities firms and brokers. We involve a number of interested parties in rulemaking deliberations so that broker-dealers and investors can have confidence they are collaborating on a level playing field. Our relationship to these participants, as well as the SEC, puts us in the unique position to guard the integrity of the market
I believe in requiring firms to reflect synthetic short positions in short interest reports. For example, enhanced short interest reporting could include synthetic short positions achieved through the sale of a call option and purchase of a put option (where the options have the same strike price and expiration month) or through other strategies. FINRA believes this information would assist FINRA
It is ludicrous to expect any self-reporting method of counting short positions to be anywhere near reliable. Organisations engaged in industrial scale naked shorting will obviously not tell the truth about their positions, especially when the fines for mis-reporting are a tiny fraction of the profits they can make. The only trustworthy method of counting shorts would be to count the shares in
Anti-Intimidation/Coordination—Failure to Comply With Rule Requirements
48
Backing Away
49
Best Execution—Failure to Comply With Requirements for Best Execution
50
Branch Offices—Failure to Register
39
Cheating, Using an Impostor,
Summary
FINRA Rule 4111 (Restricted Firm Obligations) became effective on January 1, 2022. This Notice announces that the first “Evaluation Date” for Rule 4111 will be June 1, 2022.
Questions concerning this Notice should be directed to:
Kosha Dalal, Vice President and Associate General Counsel, Office of General Counsel (OGC), at (202) 728-6903 or by email; or
Michael Garawski,
I would like to comment on two particular components of 21-19. -"It is possible that the public dissemination of more granular data could discourage short-selling activity, which is an important mechanism for both efficient pricing and for liquidity provision. We also request comment on potential negative outcomes of making this information publicly available on an aggregated basis." -
Short sellers need to be regulated and held to same standards as retail investors. Short positions time held and when returned/covered/closed should be reported publicly daily. Synthetic share shorts and naked shorting needs to be eliminated. Accountability for FTDs including who is failing to deliver and when fixed. Stop allowing shorting through ETFs.
