Regarding FINRA 21-19, this is a great start for more oversight into U.S. markets. While more attention in my opinion should be paid to the effects of short interest, I support FINRA 21-19.
leverages and short ets serve the small investor as a useful abd efficient tool to hedge risks. these options were not available until the advent of etfs. the rights of the small investor to benefit from these tools needs to be preserved.
SUGGESTED ROUTING
Senior Management
Internal Audit
Operations
Systems
Executive Summary
On February 24, 1993, the Securities and Exchange Commission (SEC) approved the NASD's new margin rules. The rules conform the NASD's margin rules to those of the New York Stock Exchange (NYSE) by replacing the current provisions of Article III,
More frequent reporting of short positions, eg weekly. Positions, trade date (open), trade date (closed), holder. Optional price and positions without showing holder.
I believe a more transparent form and frequency of short position reporting would be very beneficial to the stock market and retail investors specifically based on increased trust in the institution as a whole.
Reports on short positions should be done on a daily basis with no T+ days. In my observation, a lot of the fraud and price manipulation are able to stay hidden due to T+ days.
At a minimum we should have transparency in the market to see the same information hedge funds and market makers see also to see short positions that effect market prices
FTDs should not exist - if said security isn't delivered, liquidation is a must at agteed upon date - no more loop holes and T-#s - And 100% transparency on short positions daily
I 100% support broader and more detailed reporting on short sales. This information would lead to a fairer market through transparency and allow all parties to better understand the marketplace.
Please reconsider your proposal to limit access to leveraged and inverse funds. Many brokers do not allow shorting in IRAs hence a good alternative is the use of inverse and leveraged funds to allow an investor to hedge and protect a portfolio.