September 30, 2021

VIA ELECTRONIC SUBMISSION

Ms. Jennifer Piorko Mitchell
Office of the Corporate Secretary
Financial Industry Regulatory Authority, Inc.
1735 K Street, NW
Washington, DC 20006-1506

Re: SIFMA Comment on Short Interest Position Reporting Enhancements and Other Changes Related to Short Sale Reporting (FINRA Regulatory Notice 21-19)

Dear Ms. Mitchell:

The Securities Industry and Financial Markets Association (“SIFMA”)1 appreciates the opportunity to respond to the request for comment by the Financial Industry Regulatory Authority, Inc. (“FINRA”) in connection with FINRA Regulatory Notice 21-19 (“Reg Notice 21-19”), which contemplates changes to the short interest position reporting requirements set forth in Rule 4560 and certain other changes related to reporting information concerning short sales. As set forth in detail below, SIFMA strongly supports FINRA’s objectives of ensuring effective regulatory oversight over short sale activity to protect the markets and market participants, and welcomes discussion on potential improvements to disclosure of short sale and short interest reporting regimes. SIFMA is hopeful that its comments provided herein assist FINRA in clarifying the necessity of any improvements to the current regimes, as well as the scope of any such improvements, given other potentially duplicative regulatory initiatives and practical operational concerns imposed upon member firms. In this regard, SIFMA believes that FINRA should expand on its discussion of the goals it would be seeking to achieve through the contemplated initiatives

1 SIFMA is the leading trade association for broker-dealers, investment banks, and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s nearly one million employees, we advocate for legislation, regulation, and business policy affecting retail and institutional investors, equity and fixed income markets, and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development. With offices in New York and Washington, D.C., SIFMA is the U.S. regional member of the Global Financial Markets Association (GFMA).