Retail Shareholder Comment On Regulatory Notice 21-19
Retail Shareholder
NONE
As a retail shareholder and investor (equities and options) in multiple companies such as Tesla, Gamestop, AMC, along with the typical ETFs tracking the broader market I feel that we have not been well served by the current rules and system. The lack of transparency, limited reporting, and massive loopholes like synthetic short positions and loan obligations not being required to be reported in its current form is extremely troubling. How can the SEC and FINRA possibly ensure Reg SHO is being followed with so little data, and all data the is self reported no less? In regards to short selling, the one thing that I believe is missing is a unique identifier for each share in a central database (perhaps this is the CAT that was promised?), currently there appears to be know way to know if shares have been re-lent or created synthetically. each share must be audited and accounted for at all times post-settlement to ensure that it has not been counterfeited and if necessary buy-ins should be required. Gathering clear, transparent and actionable data is necessary for free and fair markets, some may say that providing this data could hurt their ability to protect "proprietary trading strategies", if that is the case then I say that any strategy that cannot withstand the light of day does not belong in our market. Data sharing to the public, can and should be limited, in order to protect companies and individuals but it should very much be available as needed in detail for the SEC and justice department. On the reporting of customer/institution accounts and short interest I believe must be done, to whatever level of granularity is required to be able to quickly and easily spot inappropriate behavior such as conflicts of interest. I urge FINRA to implement the rules as suggested, provide real transparency for our markets. I urge FINRA to no longer be a co-conspirator, whether knowingly or not, in attempts to fleece retail investors, mutual funds, and the American people out of future prosperity. Please institute rules that will help us have faith that our system is not corrupt, that we have a level playing field, and that the government works for us and not just wealthy and well-connected institutions and individuals. Please know that that we are all counting on you to do the right thing. Thank you
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Retail Shareholder Comment On Regulatory Notice 21-19
As a retail shareholder and investor (equities and options) in multiple companies such as Tesla, Gamestop, AMC, along with the typical ETFs tracking the broader market I feel that we have not been well served by the current rules and system. The lack of transparency, limited reporting, and massive loopholes like synthetic short positions and loan obligations not being required to be reported in its current form is extremely troubling. How can the SEC and FINRA possibly ensure Reg SHO is being followed with so little data, and all data the is self reported no less? In regards to short selling, the one thing that I believe is missing is a unique identifier for each share in a central database (perhaps this is the CAT that was promised?), currently there appears to be know way to know if shares have been re-lent or created synthetically. each share must be audited and accounted for at all times post-settlement to ensure that it has not been counterfeited and if necessary buy-ins should be required. Gathering clear, transparent and actionable data is necessary for free and fair markets, some may say that providing this data could hurt their ability to protect "proprietary trading strategies", if that is the case then I say that any strategy that cannot withstand the light of day does not belong in our market. Data sharing to the public, can and should be limited, in order to protect companies and individuals but it should very much be available as needed in detail for the SEC and justice department. On the reporting of customer/institution accounts and short interest I believe must be done, to whatever level of granularity is required to be able to quickly and easily spot inappropriate behavior such as conflicts of interest. I urge FINRA to implement the rules as suggested, provide real transparency for our markets. I urge FINRA to no longer be a co-conspirator, whether knowingly or not, in attempts to fleece retail investors, mutual funds, and the American people out of future prosperity. Please institute rules that will help us have faith that our system is not corrupt, that we have a level playing field, and that the government works for us and not just wealthy and well-connected institutions and individuals. Please know that that we are all counting on you to do the right thing. Thank you