March 14, 2022
I am an individual retail investor.
I believe that reporting short positions should be made as uncomplicated as possible. Reporting managers should have stricter reporting periods. I cannot speak on to the universe of securities that should be reported, however, from what I've seen about the short sales, I believe all short sales should be reported as it is too easy for a short sale to be naked.
Any security that can have derivatives should have reporting requirements, including fixed income.
ETF's need more regulation and increased reporting requirements may help. I think more stringent regulation, such as the inability for Authorized Participants (AP's) to create unlimited shares from etf baskets seems abusive.
I support that reporting managers must
Calculate gross short positions in equity securities.
I believe that reporting managers may able to use derivatives to circumvent regsho, and therefore they must also be included in the report.
Both puts and calls, while only one type of derivative, can be used to create synthetic positions so I believe all types of derivatives can be abused if not properly regulated.
For Q8 I believe reporting managers absolutely must report their net derivative positions, both long and short. The only con with this is that it's monthly and not weekly. It should be weekly, or at least once every two weeks.
For Q9 ETF's absolutely need to be including in reporting requirements. I can't speak to the types of activities in the other parts of the question as no one teaches retail this stuff, I gotta figure it out myself.
Q10: I believe reporting managers should be required to consider ETF short positions when shorting an ETF to not cause compounding positions that may not trigger regsho otherwise.
Q11: I explained earlier that reporting should be made at the very minimum twice a month and should be given one week to submit the necessary documents. Pardon my language, but a lot of fuckery can happen in one month+14 days.
Q28: it has been shown in the past through FINRA's violation reporting that in many cases reporting managers will recklessly or intentionally mismark a position that's short as a long position. Making the assumption that it's an equal 1-to-1 of short+short exempt to buy-to-cover is dubious. There needs to be an assumption that the reported numbers are an under-estimate.
Thank you for your work. I appreciate the platform given to retail to voice opinions and concerns. Rocket emoji rocket emoji rocket emoji