I strongly support stricter reporting requirements on short positions held by market makers and prime brokerages. It is increasingly necessary that FTD information be presented to the public as a way of not only limiting abuse of the FTD system, but also to reveal obfuscated information that is not readily available to the market and is often times concealed or miscategorized in reporting.
I have traded these leveraged and inverse funds for many years. They should be available to all not select few. The test is just another unnecessary bureaucratic hurdle for people who can read and understand the risk. These funds are useful in short term trading as an overnight or 2-3 day vehicle that can be used with less leverage than a futures contract. Your consideration appreciated.
I believe as an experienced investor that I should be able to use leveraged funds to enhance returns on my portfolio or in the case of inverse funds to hedge and protect on the downside for my portfolio. If not allowed to choose my only option would be to open a margin account and use leverage open myself to possibility of margin calls or to potentially short a stock that has unlimited risk.
Accurate short sale tracking is important, but it’s only as useful as the information given on dark pool activities. Dark pool existence, and how those exchanges are able to integrate shares into major exchanges is beyond fraudulent. I appreciate your efforts, but share selling will never be put into check until dark pools are eliminated.
FINRA Requests Comments on Proposed Consolidated FINRA Rules Governing Securities Loans and Borrowings, Permissible Use of Customers' Securities and Callable Securities
There is a lot of "considerating" in the text above. The main point is transparency here and he need for more regular reporting. we are living in the digital era; there should be reporting of short positions every day or at the bare minimum every other day. A week is still too long to wait. Retails positions are known and not hidden.
Every share should be tracked with unique identifier. Every share should be located and lent only once. Every order should be delivered T+2 or fails mean 10x cost penalty and trading permission halted until delivered. Every short position should be updated with FINRA daily and publicly available.
SUGGESTED ROUTING*
Senior ManagementLegal & ComplianceOperationsSystemsTrading
*These are suggested departments only. Others may be appropriate for your firm.
EXECUTIVE SUMMARY
As previously reported in Notice To Members 88-104, the NASD, beginning February 12, 1989, will require its members to respond to requests for trading data using an automated format. The format is consistent
(a) A member shall submit the trade data specified below in automated format as may be prescribed by FINRA from time to time. This information shall be supplied with respect to any transaction or transactions that are the subject of a request for information made by FINRA.
(b) If the transaction was a proprietary transaction effected or caused to be effected by the member for any account in
I don't believe FINRA even has the capabilities to create a fair and free market as what we have is the literal opposite. If you do, no one has seen it. Synthetic shares are created by the millions with no regulation or repercussion. Shares are traded in dark pools by market makers, then shorted in lit pools to crippled and drive down the price of stocks for market makers and institutions
