This is exactly how I understood it, Finra twice a month only with the settlement date (don't forget T+2) counts, has nothing to do with Daily shorts, I'm showing 2 million shares shorted today the 15th, Finra will report trades as of Friday the 11th T+2 for the 15th. It will be interesting to see how this plays out between now and the end of the month with that wildcard distribution that will not include those 2 Million shorted shares. If they can convince enough holding to sell they can cover without pushing it up. Friday the 25th and the 28th should be some crazy days here folks.
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For example, suppose that for security ABCD, FINRA published a combined short sale volume of 3,000 shares and total volume of 15,000 shares for all of its trade reporting facilities.7 Viewing only this off-exchange data published by FINRA, the percentage of short sale volume to total volume would appear to be 20%. Suppose, however, that there was also activity for ABCD executed on the New York Stock Exchange (NYSE) that day totaling 125,000 shares, of which 12,000 shares were reported as short. This volume is published by NYSE on its website, separate from the volume published by FINRA. When considered together, the overall percentage of short sale volume to total volume for ABCD that day is 10.7%, which is much lower than the data published on the FINRA website would suggest.
FINRA notes that the SEC has a webpage where market participants can find links to the short sale volume data published by FINRA and the exchanges,8 which may facilitate consolidation of the data and provide market participants a more complete picture. However, some exchanges charge a fee for access to their data.9
Finally, short sale volume data does not—and is not intended to—equate to reported bi-monthly short interest information. FINRA rules require firms to report, on a per security basis, the total quantity of shares held as short positions in all customer and proprietary firm accounts twice a month. FINRA publishes the short interest data for OTC equity securities on its website, while the data for listed stocks is published by the exchange on which the stock is listed. Although some websites redistribute the Daily File and refer to the data as “short interest,” it is not, in fact, the equivalent of reported short interest information.
Some market participants mistakenly conclude that the bi-monthly short interest data is understated because the Daily File reflects short sale volume that is much larger than what is reported as short interest. However, short interest data reflects short positions held by market participants at a specific moment in time on two discrete days each month, while the Daily File reflects the aggregate volume of trades executed as short sales on each trade date. Therefore, while the two data sets are related (i.e., short sale volume may ultimately result in a reportable short interest position), they are not necessarily correlated.
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