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 for the fair, accurate, and timely reporting of Short sales, cumulate short positions, individual ticker short interest, and options-implied float. Short selling remains the greatest checkmark against Daedalic-hubris of a Bull market, and it serves even more prominently as the greatest check mark against illegitimate capital siphoning to illegitimate corporations. In short, short selling serves as a sword and shield against corruption on the stock market that is wielded by the market. For this, it can be seen as a wholly necessary evil. If short selling is to exist as Lilith's flaming sword, expelling the wicked and unjust from the market, then let it be wielded freely. If fair is unavailable, free is the next best thing. Complete transparency with expedient delivery of crucial information allows for the market to check against the market, individual corporations, but also individual members who would cast stones. Barring more modern legal precedent, let he who casts the first stone be judged maintains it's prominence for ethos. By forcing all shorting entities (both broker-dealers and individual short seller) to deliver short sale information by end of day, it allows the entire market to ensure an equal and just playing field. Furthermore, this creates an open-source team for FINRA investigators to utilize in identifying malevolent parties who would abuse the system. The following brief list is the sum of necessary information that should be reported no later than end of day for every entity committing a short sale: 1) Short sale share count total and net (buybacks subtracted) for day and total. 2) Matching derivative positions, such as matched put/calls that might be indicative of phantom share creation. 3) All non-short positions for the same stock. (Catch out blatant pump and dumpers). 4) Matching data confirmation from all broker-dealers maintaining an accurate total share count of every ticker's float. While much of this information is unreliable without composite honesty from banking institutions, these steps would move the market in a drastic direction towards healing. By keeping this information public, accurate, and updated, the market can keep check on the market. The end results of a massive increase in transparency of short selling could be as bold as less frequent equities runs, fairer price discovery, less banking/financial liquidity and collateral crises, and a healthier stock market allowing fair and just capital allotment for the companies that drive technology, science and humanity forward. Always, Josef Grey
Josef Grey Comment On Regulatory Notice 21-19
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 for the fair, accurate, and timely reporting of Short sales, cumulate short positions, individual ticker short interest, and options-implied float. Short selling remains the greatest checkmark against Daedalic-hubris of a Bull market, and it serves even more prominently as the greatest check mark against illegitimate capital siphoning to illegitimate corporations. In short, short selling serves as a sword and shield against corruption on the stock market that is wielded by the market. For this, it can be seen as a wholly necessary evil. If short selling is to exist as Lilith's flaming sword, expelling the wicked and unjust from the market, then let it be wielded freely. If fair is unavailable, free is the next best thing. Complete transparency with expedient delivery of crucial information allows for the market to check against the market, individual corporations, but also individual members who would cast stones. Barring more modern legal precedent, let he who casts the first stone be judged maintains it's prominence for ethos. By forcing all shorting entities (both broker-dealers and individual short seller) to deliver short sale information by end of day, it allows the entire market to ensure an equal and just playing field. Furthermore, this creates an open-source team for FINRA investigators to utilize in identifying malevolent parties who would abuse the system. The following brief list is the sum of necessary information that should be reported no later than end of day for every entity committing a short sale: 1) Short sale share count total and net (buybacks subtracted) for day and total. 2) Matching derivative positions, such as matched put/calls that might be indicative of phantom share creation. 3) All non-short positions for the same stock. (Catch out blatant pump and dumpers). 4) Matching data confirmation from all broker-dealers maintaining an accurate total share count of every ticker's float. While much of this information is unreliable without composite honesty from banking institutions, these steps would move the market in a drastic direction towards healing. By keeping this information public, accurate, and updated, the market can keep check on the market. The end results of a massive increase in transparency of short selling could be as bold as less frequent equities runs, fairer price discovery, less banking/financial liquidity and collateral crises, and a healthier stock market allowing fair and just capital allotment for the companies that drive technology, science and humanity forward. Always, Josef Grey