SIFMA provides comments to the Securities and Exchange Commission (SEC) on the Financial Industry Regulatory Authority, Inc.’s (FINRA’s) proposal to amend FINRA Rule 4560, which sets forth requirements in connection with short interest reporting, File No. SR-FINRA-2012-001, Exchange Act Release No. 66220.  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. In addition, SIFMA 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.