"FINRA is considering: (1) modifications to its short interest reporting requirements (Rule 4560); (2) a new rule to require that participants of a registered clearing agency report to FINRA information on allocations to correspondent firms of fail-to-deliver positions; and (3) other potential enhancements related to short sale activity. FINRA believes that these potential changes could
Fractional short shares must be included in reported short interest else the rule is pointless. Truncating will allow 10billion .5 shares to go unreported and should legally be reported as 5 billion short
While short sales can be an important market mechanic to send signals to protect investors from corrupt or inept corporate leadership, hidden short sales and hidden synthetic short sales work against a free and fair marketplace. If institutional and "big money" investors detect reasons to believe that the future success of a company is unlikely, hiding their short positions at best
Appropriate reporting requirements on short sales, institutional short selling and dark pool sales reporting. Outdated reporting requirements allows for the current institutional deceitfulness in its short selling practices
What implementation period would be appropriate to provide members with sufficient time to make the systems changes necessary to comply with this requirement? Change needs to happen as soon as possible, immediately to restore faith in the markets. To make these crooked markets somewhat fair to retail investors. FINRA is considering whether daily or weekly short interest position reporting would
We want better short sell reporting, end of day settlements, better short sell marking of shares, much stronger penalties or jail time for short sell violations, and market manipulation
Publication Date: February 23, 2023
Interpretations are marked in blue background beneath the rule text to which they relate.
15c3-3b Exhibit B - Formula for determination of security-based swap customer reserve requirements of brokers and dealers under § 240.15c3-3.
Credits
Debits
1.
Free credit balances
SUGGESTED ROUTING
Senior Management
Advertising
Continuing Education
Corporate Finance
Executive Representatives
Government Securities
Institutional
Insurance
Internal Audit
Legal & Compliance
Municipal
Mutual Fund
Operations
Options
Registered
1. Open institutional short positions should be disclosed after the end of every market close. 2. Shares in an institutional short position should be serialized in order to attempt to prevent rehypothication and to confirm the shares exist. 3. Failure to delivers should be disclosed within 1 day after the settlement date. 4. The penalty for not reporting information on open short positions or
SUGGESTED ROUTING*
Senior ManagementLegal & complianceOperationsRegistration
*These are suggested departments only. Others may be appropriate for your firm.
EXECUTIVE SUMMARY
The 1988-89 NASD broker-dealer and agent registration renewal cycle will begin in early November. This program allows for simplification of the renewal process through the payment of one invoice amount that
