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patchman

10/04/10 10:23 AM

#330874 RE: starfire #330873

feel free to post that rule - specific language and link - as that is not the case that I am aware of. Short Sales are reported whether they be client short sales, house positions, or bona-fide market making short sales. The only non-reported short sales are non-member firms.

The Haverford quote you cited was not about reporting short sale sales but about reporting who is teh owner of the FTD.
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patchman

10/04/10 11:19 AM

#330881 RE: starfire #330873

In case you did not find it....

General Instructions for Short Interest Reporting

December 18, 2008



TO:

Member Firms


FROM:

Market Regulation Department


RE: Short Position Reporting



Regulation Filing Applications Instructions

Pursuant to FINRA Rule 4560, member firms are required to report total short positions in all customer and proprietary firm accounts in OTC equity securities and securities listed on a national securities exchange, such as NASDAQ, NYSE, NYSE Alternext US LLC1 and NYSE Arca, to FINRA on a bi-monthly basis. These filings are made online via the Regulation Filing Applications (RFA) system at https://regfiling.finra.org.

All firms that report short interest to FINRA are responsible for maintaining current and previous-cycle short interest reports pursuant to SEC recordkeeping requirements. The RFA system is the only method for reporting the firm’s proprietary and customer short positions in NASDAQ, NYSE, NYSE Alternext US LLC, NYSE Arca and OTC equity securities. If your firm notes any discrepancies in the filing of its short interest report or has any reporting questions, please contact Yvonne Huber at (240) 386-5034 or Michele Bowan at (240) 386-4986. Please direct questions about entitlement or access to the system to your firm’s account administrator. If you do not know who your account administrator is, please contact the FINRA Call Center at (301) 590-6500.



General Instructions

Member firms that have short positions in OTC equity securities and in securities listed on a national securities exchange, such as NASDAQ, NYSE, NYSE Alternext US LLC and NYSE Arca must file a Short Position Report with FINRA via the Web-based RFA system. The application will accept filings for the current reporting period as of 8 a.m. Eastern Time (ET) on the designated settlement date.

Each member firm must file a Short Position Report with FINRA for each reporting period to report total short positions for all customer and proprietary accounts maintained at the firm.

The Reporting Period: Firms must report their mid-month short positions as of the close of business on the settlement date of the 15th of each month or, where the 15th is a non settlement date, on the preceding settlement date. Firms must report their end-of-month short positions as of the close of business on the last business day of the month on which transactions settle.

The Filing Date: Filings must be received by FINRA by 6:00 p.m., ET, on the designated due date, which is the second business day after the designated settlement date.

Short Interest Reporting: Short positions for all firm accounts, including those for the firm’s partners/officers, employees and customers must be reported. The report should list, in alphabetical order, the relevant exchange/market code, issue symbol, security name, and number of common shares, preferred shares, warrants, units or ADRs short for the current reporting period as of the designated settlement date. Firms should report only whole numbers of shares, and not decimals or fractional shares.

Firms are required to designate the appropriate exchange or market code, as of the designated settlement date, for each issue symbol and short position reported.2 Firms must append the appropriate exchange or market code to the corresponding issue symbol that represents the primary exchange or market on which the security is listed in the United States as of the designated settlement date.3 For a temporary period, beginning with the June 30, 2008 short interest reporting settlement date, the only exchange/market codes that will be accepted by RFA are as follows: