SIFMA provided comments to the SEC Commission (SEC) on FINRA's proposal to amend FINRA Rule 4560, which sets forth requirements in connection with short interest reporting - as submitted to the Commission under Rule Filing 12-01. SIFMA recommends essential adjustments to the proposal designed to rationalize and enhance the efficiency with which member firms systematically report short positions based on gross short positions as reflected in the stock record. SIFMA further recommends narrowing the exception from the proposal's reporting requirements for sales of certain “owned” securities, to allow firms to more efficiently and properly report short interest, while still serving the policy objectives of the proposal. The 7-page comment letter was prepared on SIFMA's behalf by Melissa MacGregor, Managing Director & Associate General Counsel. For further details, go to:   [SIFMA Comment Letters, 2/23/12].