Hello, my name is Justin Darrow. I'm pleased to see you're requesting feedback on how to make the stock market more fair, something the SEC doesn't seem to do. When it come to short interest positions, there are 3 things I'd love to see besides the wonderful things you mentioned 1. A T+0 settlement would obviously be the best option. Atleast after market close but buy orders,
NASD® has taken disciplinary actions against the following firms and individuals for violations of NASD rules; federal securities laws, rules and regulations; and the rules of the Municipal Securities Rulemaking Board (MSRB).
The once a month short reports a a dis advantage to a ll traders. They can short more that 100% and we should be able to find out what the short interest is at will.
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to the edge of disaster, in large part due to systemic risk developed under the regulatory authority of FINRA's outdated short interest reporting policy.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
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Senior Management
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REQUEST FOR COMMENTS
EXECUTIVE SUMMARY
The NASD is requesting comment on a proposed amendment to the Board of Governors' Interpretation on Prompt Receipt and Delivery of
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
As a retail investor, I firmly believe that the market NEEDS more transparency and regulation. If the FINRA is going to collect information on short interest accounts, arraigned financing agreements, and Failure or To Delivers, they should collect as much information as possible and retail investors should be able to use that information to make informed decisions. A. Publication of Short
FINRA 21-19 addresses many of the shortcomings of our opaque market. While I support the reporting enhancements, I would like to see further action taken by FINRA to bring transparency to short selling. Short selling, while providing liquidity to the market, also brings the challenge of unlimited risk. Unlimited risk (e.g. a short squeeze) drives market participants to engage in unethical and
If there was more transparency into short seller positions paired with the proposed enhanced reporting practices it could encourage a more fair market for all investors, not just those largest participants. When attempting to do research into short positions into some companies I had a long position in, the information was so sparse, and vague to say the least, you could not accurately assess the
"Synthetic Short Positions: In addition, FINRA is considering requiring firms to reflect synthetic short positions in short interest reports." This should be implemented as a daily report with no T+ days.
