Dear FINRA Committee members, It is this commenter's genuine hope that short selling is banned as it serves counter-purpose to the two primary functions of the Stock Market, Capital Allotment, and Price Discovery. As such an act would likely remove the need for FINRA, and it is unjust to request this forum to consider self-destruction. Instead, this comment hopes to serve as a basic appeal
Q1. Is a firm required to report on the OBS the market value of underwriting commitments entered into on a “best efforts” basis?
A1. No. Underwriting commitments entered into on a “best efforts” basis are not required to be reported on the OBS.
Q2. If a member firm enters into an agreement with a customer or other party, whereby it commits to lend up to a specified dollar amount, whether such
Retail investors do not typically have much to say during these critical junctures in financial history, but given the recent tumultuous events of the last year, and the potential systematic failures that can be eliminated by 21-19, I felt the need to lend my voice to the effort. Regardless of the viability of short selling as a legitimate investment strategy, the inefficacies introduced by short
Please approve the new rules to tighten up short interest reporting requirements. There are too many loopholes that short traders use to hide and obfuscate their true short interest (eg hiding shorts in deep OTM put contracts) which puts retail traders at an information disadvantage, which is anathema to free market principles.
To me, it is absolutely absurd that short positions are not required to be reported. If you require long positions to be reported, why shouldn't short positions? It seems as though the regulators are far too concerned with keeping the status quo and are letting hedge funds run wild, in a largely unregulated portion of the market. We have seen numerous short squeezes this year arising from
Anytime reported shorting goes from a high percentage to a lower one without any sign of short squeezing and the price of a stock continues to drop, should immediately trip a signal to report for investigation. For instance, when AMC was showing a reported shorting percentage of over 18% on July 6th and then today, the 13th, the stock drops drastically and shows it’s now 15% shorted from borrowed
Make short selling more transparent (e.g daily data). Participants have to file in the long positions, but not the shorts, why? Disallow "data manipulation" by fake covering with worthless deep OTM options. Remove loopholes based on T+2 settlement. Why even T+2? Make it T+0 already. Why allow shorting of stocks on the security threshold list by short excempt? It seems not appropriate to
I agree with the proposed changes. Data on Short positions should be reported every day including synthetic short positions/naked shorts.
Consolidation of short interest data publication, centralized on the FINRA website should be made public. Require firms to segregate short interest held in proprietary accounts vs that held in customer accounts. Report to FINRA account-level short interest (not for publication). Report synthetic short positions in both options and security based swaps. Report loan obligations from arranged
FINRA 21-19 is a long overdue change. 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. While many of the policies mentioned in Regulatory Notice 21-19 address the general breadth of exploitable and ineffective
