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Mike Hawk Comment On Regulatory Notice 21-19

Mike Hawk
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The current practice of short interest reporting is flawed, as Market Makers are legally allowed to naked short for the sake of liquidity, and have means to "clear" FTD's without needing to buy the underlying stock. The enhancements proposed by FINRA would greatly enhance the visibility of short interest in the market, and allow investors to choose stocks wisely while being able to see the bigger picture, which historically has been kept from them. "Under current Rule 4560, firms report to FINRA the gross short interest in a security aggregated across all accounts twice a month. Firms have two business days after the settlement date to submit the reports. The data do not distinguish the type or identity of accounts with short positions. The data also do not reflect short positions that are achieved synthetically or loan obligations resulting from arranged financing. " In todays day and age, the short interest report should not only be available twice a month. A decrease to the wait times between short interest reports would be greatly appreciated.