A. Providing short interest information to the public for free is a requirement to ensure the retail public's trust in the market. Without access to this information, the average retail investor is at a huge disadvantage when it comes to making trading decisions. Finra should take charge and publish this information daily, so retail investors can make timely decisions about their trading strategy and not have to guess based on data that is two weeks old by the time it is released. The economic costs of providing more transparency to the market are far outweighed by the positive public sentiment gained. B. Gathering information upfront about specific accounts that hold specific short positions would make investigation and prosecution of improperly executed short positions easier and would help discourage any illegal or questionable practices. However, I do not believe disseminating this information publicly would be of any benefit. I would prefer if each share had a unique identifier and each short must be paired with a unique identifier prior to being allowed to be executed. This would cut down on failure to delivers and synthetic shares that have no intention of being legitimized. Arranged financing and synthetic shares should not be allowed at all. It floods the market with an excess of shares equal to or many times greater than a traditional share dilution. It then becomes a self fulfilling prophecy. Just as a stock split or share dilution would lower the price of a stock, the very act of shorting shares that only exist on paper, or covering short positions by borrowing additional shares increases the total share supply which has a negative affect on the price as it shifts the supply/demand curve, regardless of actual total sentiment in the stock price. Including TSO, Public Float, and Threshold Security status would also be helpful. But at the end of the day shorting with synthetic shares or borrowing shares to cover a borrowed share hurts investors, businesses, and our economic growth in general. C. Please collect short interest data daily, as this would be of the greatest beneficial impact to investors. D. Please pursue daily FTD reports. FTD has gotten out of hand, especially in regards to so called "meme" stocks. For instance, AMC and GME routinely have FTD's hundreds or thousands of times more than other large companies, like MSFT, for instance. This creates a level of distrust and opacity in the market that is detrimental to the public's confidence in the market. Overall, again, I'd like to see shares have a unique identifier to prevent shorting shares that do not exist and for synthetic shares to be disallowed as proof for covering a short position, since there's no requirement they actually execute those trades.
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Christen W. Comment On Regulatory Notice 21-19
A. Providing short interest information to the public for free is a requirement to ensure the retail public's trust in the market. Without access to this information, the average retail investor is at a huge disadvantage when it comes to making trading decisions. Finra should take charge and publish this information daily, so retail investors can make timely decisions about their trading strategy and not have to guess based on data that is two weeks old by the time it is released. The economic costs of providing more transparency to the market are far outweighed by the positive public sentiment gained. B. Gathering information upfront about specific accounts that hold specific short positions would make investigation and prosecution of improperly executed short positions easier and would help discourage any illegal or questionable practices. However, I do not believe disseminating this information publicly would be of any benefit. I would prefer if each share had a unique identifier and each short must be paired with a unique identifier prior to being allowed to be executed. This would cut down on failure to delivers and synthetic shares that have no intention of being legitimized. Arranged financing and synthetic shares should not be allowed at all. It floods the market with an excess of shares equal to or many times greater than a traditional share dilution. It then becomes a self fulfilling prophecy. Just as a stock split or share dilution would lower the price of a stock, the very act of shorting shares that only exist on paper, or covering short positions by borrowing additional shares increases the total share supply which has a negative affect on the price as it shifts the supply/demand curve, regardless of actual total sentiment in the stock price. Including TSO, Public Float, and Threshold Security status would also be helpful. But at the end of the day shorting with synthetic shares or borrowing shares to cover a borrowed share hurts investors, businesses, and our economic growth in general. C. Please collect short interest data daily, as this would be of the greatest beneficial impact to investors. D. Please pursue daily FTD reports. FTD has gotten out of hand, especially in regards to so called "meme" stocks. For instance, AMC and GME routinely have FTD's hundreds or thousands of times more than other large companies, like MSFT, for instance. This creates a level of distrust and opacity in the market that is detrimental to the public's confidence in the market. Overall, again, I'd like to see shares have a unique identifier to prevent shorting shares that do not exist and for synthetic shares to be disallowed as proof for covering a short position, since there's no requirement they actually execute those trades.