I am encouraged that you are considering changes on the subjects of Short Interest Position Reporting Enhancements and Other Changes Related to Short Sale Reporting. These changes are will open the way to fair market operations. In the current environment the technology and information for market operations is far superior compared to what is available to regulators and ultimately the public. That tech is being abused in an aggressive manner which is in turn creating blind risks for the investing public. While sweeping changes take time, I would hope you can communicate a roadmap in a short time including the following changes: - ability to identify/track lots/individual shares of any company with a 'serial #' - ability to accurately identify and balance the book of shares for each company - ability to execute the above on a weekly, daily, hourly and/or real time basis I understand this has to be done in collaboration with other market participants but, at the very least it would align us in the right direction.
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Sean B Comment On Regulatory Notice 21-19
I am encouraged that you are considering changes on the subjects of Short Interest Position Reporting Enhancements and Other Changes Related to Short Sale Reporting. These changes are will open the way to fair market operations. In the current environment the technology and information for market operations is far superior compared to what is available to regulators and ultimately the public. That tech is being abused in an aggressive manner which is in turn creating blind risks for the investing public. While sweeping changes take time, I would hope you can communicate a roadmap in a short time including the following changes: - ability to identify/track lots/individual shares of any company with a 'serial #' - ability to accurately identify and balance the book of shares for each company - ability to execute the above on a weekly, daily, hourly and/or real time basis I understand this has to be done in collaboration with other market participants but, at the very least it would align us in the right direction.