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Joshua Scott Comment On Regulatory Notice 21-19

Joshua Scott
N/A

FINRA 21-19 will help to restore some of my confidence in the US financial markets. I say some because 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to the edge of disaster, in large part due to systemic risk developed under the regulatory authority of FINRA's outdated short interest reporting policy. Healthy markets benefit everyone in the long term. Given the abuses I have seen, I have decided to remove all of my investments from the market unless substantial changes are enacted. While many of the policies mentioned in Regulatory Notice 21-19 address the general breadth of exploitable and ineffective reporting, they also leave significant specific gaps that could compromise the entirety of 21-19's purpose. It is critical for the restoration of both the stability of the US markets and the confidence of the investors within it that any and all regulation changes regarding short interest reporting be effective in every known circumstance where effective short positions, synthetic or not, can go unaccounted for for any length of time greater than any other short position reporting deadline. Additionally, the cost of operations necessary for applicable market members to accommodate these standards cannot be reasonably compared to the cost of a compromised market with systemic risk or the loss of investor confidence and participation in the US economy. The US markets have long been the strongest and most prosperous in the world, but that position is eroding. We need a good regulations to restore confidence. Please close all gaps and loopholes in this or you risk losing millions of investors such as myself.