Short-Interest Reporting
Quick Answer
The FINRA short-interest reporting requirement obligates every member firm to report short positions in all equity securities to FINRA twice each month: as of the 15th (or prior settlement day if the 15th is not a settlement day) and as of the last business day of the month. Reports are due by 6:00 p.m. ET on the second business day after the reporting settlement date. Only settled short positions as of the close of the reporting settlement date are reported. Substantive short-sale rules live in Reg SHO, not the short-interest reporting requirement.
The short-interest reporting requirement is the data-collection rule for short positions in the equity market. FINRA aggregates the data and publishes short-interest figures by symbol, which become input to market-color reports, surveillance systems, and academic / industry research. The rule itself is a reporting rule, not a substantive short-sale rule. The substantive rules (locate requirement, marking requirement, close-out, threshold-security restrictions) live in Reg SHO.
Twice-Monthly Reporting Cadence
Members must report short positions on a bi-monthly schedule:
| Reporting Date | Settlement Date | Filing Deadline |
|---|---|---|
| Mid-month | Position as of the 15th (or prior settlement day) | 6:00 p.m. ET on the second business day after the reporting settlement date |
| Month-end | Position as of the last business day | 6:00 p.m. ET on the second business day after the reporting settlement date |
What "Settlement Day" Means
The reporting "settlement day" is the trade date plus the settlement period. Under the post-2024 T+1 settlement cycle, settlement is one business day after trade.
If the 15th is a Saturday or Sunday (or a market holiday), the reporting date moves to the prior settlement day. So a March 15th that falls on a Sunday would shift the mid-month reporting date to Friday March 13th's settlement (Monday March 14th).
Filing Deadline: 2 Business Days, 6:00 p.m. ET
Reports are due by 6:00 p.m. Eastern Time on the second business day after the reporting settlement date:
- Mid-month settlement date is Tuesday March 15 → report due Thursday March 17 by 6:00 p.m. ET
- Month-end settlement date is Friday March 31 → report due Tuesday April 4 by 6:00 p.m. ET (skipping the weekend)
Exam Tip: Gotchas
- Short-interest reporting is BI-MONTHLY (twice each month), not monthly. The two reports cover the 15th and the last business day. The exam may try to trip students up with "monthly" or "weekly"; the cadence is twice each month.
- Reports are due at 6:00 p.m. ET on the SECOND business day after the reporting settlement date. Common exam trap: students remember "2 business days" but forget the 6:00 p.m. ET cutoff.
Reportable Positions: Settled Shorts Only
Only settled short positions as of the close of the reporting settlement date are reportable.
What "Settled" Means
A short sale is "settled" when:
- The trade has been executed and confirmed
- The settlement date has passed
- The seller has delivered the shares (typically borrowed shares delivered against the sale)
Unsettled short sales (trades executed but not yet settled, or trades with settlement failures) are NOT included in the short-interest report.
Equity Securities Scope
The rule covers all equity securities, including:
- Listed equities (NYSE, Nasdaq, NYSE American)
- OTC equities reported through the OTC Reporting Facility
- Securities not reported elsewhere
The reporting captures both exchange-listed and OTC short positions. FINRA aggregates the data across all reporting members.
Exam Tip: Gotchas
- Only SETTLED short positions are reported. A short sale executed yesterday but not yet settled is NOT in the report. Common exam confusion: students assume "current" short positions include unsettled trades; they do not, for short-interest reporting purposes.
Short-Interest Reporting vs. Reg SHO: Reporting vs. Substantive Rules
A frequently tested distinction:
| Rule | Function |
|---|---|
| Short-interest reporting requirement (FINRA) | Reporting rule: tells FINRA which short positions are open and how big they are |
| Reg SHO (SEC) | Substantive rule: tells firms how to mark short sales, locate borrowable shares, close out failures, and respond to threshold-security restrictions |
The short-interest reporting requirement surfaces the data; Reg SHO sets the conduct rules. The two rules govern different layers:
- A firm with a perfectly reported short-interest position can still violate Reg SHO if it failed to mark the sale correctly, did not have a reasonable locate, or failed to close out a fail-to-deliver within the required window
- A firm with perfect Reg SHO compliance can still violate the short-interest reporting requirement if it missed a 6:00 p.m. ET filing deadline
Exam Tip: Gotchas
- The short-interest reporting requirement is a REPORTING rule; it does not impose substantive short-sale restrictions. Substantive short-sale rules are in REG SHO, which governs locate, marking, close-out, and threshold-security restrictions. The reporting rule surfaces the data; Reg SHO sets the conduct rules.
- Reg SHO's marking framework requires every sale to be marked long, short, or short exempt. A firm that incorrectly marks a sale violates Reg SHO; the short-interest report is built off the (correctly or incorrectly) marked positions. The exam may probe how the marking framework and the short-interest reporting interact.
How the Short-Interest Data Is Used
FINRA aggregates short-interest reports across all members and publishes summary short-interest data by security. The published data feeds:
- Market-color reports tracking which stocks have building or shrinking short interest
- Surveillance systems flagging unusual short-interest growth (often a signal of pending bad news or coordinated trading)
- Academic and industry research on short-interest dynamics
- Public investor information (FINRA publishes basic short-interest data)
For the firm side, short-interest reporting is operational: the firm runs an automated extract of its short-position data twice a month and submits it within the 2-business-day / 6:00 p.m. ET window. Failures are typically operational (system bug, missed deadline) rather than substantive.