As a concerned investor and with regard for the overriding desire for free, fair and open markets, I return the following comments. 1. Consolidation of short interest data publication, centralized on the FINRA website should be made public. 2. Require firms to segregate short interest held in proprietary accounts vs that held in customer accounts. 3. Report to FINRA account-level short interest (not for publication). 4. Report synthetic short positions in both options and security based swaps. 5. Report loan obligations from arranged financing to better reflect actual short sentiment. 6. Report total shares outstanding and the public float. 7. Daily reporting timeframe. 8. A daily report of FTD allocations at the security level. 9. Create a reporting framework around stock lending activity.
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USA Investor Comment On Regulatory Notice 21-19
As a concerned investor and with regard for the overriding desire for free, fair and open markets, I return the following comments. 1. Consolidation of short interest data publication, centralized on the FINRA website should be made public. 2. Require firms to segregate short interest held in proprietary accounts vs that held in customer accounts. 3. Report to FINRA account-level short interest (not for publication). 4. Report synthetic short positions in both options and security based swaps. 5. Report loan obligations from arranged financing to better reflect actual short sentiment. 6. Report total shares outstanding and the public float. 7. Daily reporting timeframe. 8. A daily report of FTD allocations at the security level. 9. Create a reporting framework around stock lending activity.