The additional transparency and short interest reporting rules that FINRA is proposing are a welcome start. All short interest reporting should be made available to the public for 2 reasons. First, this information directly impacts all investors. Second, it is clear that there is no way possible for FINRA, SEC or any other regulator to police the markets. By making all reported short interest information public will lead to a more transparent and therefore a more fair market. In addition to the proposed reporting enhancements, I would strongly encourage FINRA to look at the laws governing short sales. For example, an institution can use synthetic shorts to create a short position that is more than 100% of the float for a given stock. Why is this even allowed? Shouldn't there be limits? Why are naked short positions allowed at all, even for short durations? Institutions abuse the settlement periods and the failure to deliver rules constantly to manipulate stock prices. Why is this allowed? How is this fair to the individual investor? In summary, the proposed reporting changes are a good step in the right direction, but there are much bigger steps needed to fix a manipulated and unfair market.
Tony Comment On Regulatory Notice 21-19
The additional transparency and short interest reporting rules that FINRA is proposing are a welcome start. All short interest reporting should be made available to the public for 2 reasons. First, this information directly impacts all investors. Second, it is clear that there is no way possible for FINRA, SEC or any other regulator to police the markets. By making all reported short interest information public will lead to a more transparent and therefore a more fair market. In addition to the proposed reporting enhancements, I would strongly encourage FINRA to look at the laws governing short sales. For example, an institution can use synthetic shorts to create a short position that is more than 100% of the float for a given stock. Why is this even allowed? Shouldn't there be limits? Why are naked short positions allowed at all, even for short durations? Institutions abuse the settlement periods and the failure to deliver rules constantly to manipulate stock prices. Why is this allowed? How is this fair to the individual investor? In summary, the proposed reporting changes are a good step in the right direction, but there are much bigger steps needed to fix a manipulated and unfair market.