Jan. 28, 2023
January 28, 2023 Dear SEC, 1) FTD Reporting The SEC should push for publishing Fail-to-Deliver (FTD) data for all securities on a daily basis and on a publicly accessible web site. The way that FTD data is provided currently, is obnoxious, not user-friendly, and suggests an optimizable user experience for interested parties who want to access FTD data for U.S. securities. Publication frequency of FTD data should be on a daily basis. An optimized FTD reporting standard should also make transparent overlaps of FTDs between various U.S. securities, such as, e.g. company stocks and ETF shares. 2) FINRA Rule 4560 Short-Interest Reporting FINRA Rule 4560 must absolutely include reporting requirements for non-FINRA members, if they have holdings in U.S. corporations that are publicly traded on one of the U.S. stock exchanges. 3) Obligations Warehouse Last but not least, it would be amazing if the transactions in NSCC's Obligations Warehouse (OW) could be made publicly available on a daily basis to make transparent securities prices and counterparties involved in OW transactions. Thank you for considering my suggestions. Please note that we are here, we are educated, and we are not leaving. Sincerely, Brandon O'Shaughnessy