July 29, 2008
As an independent investor who believes in the power and importance of TRANSPARENCY in public markets I think it is very import to update the frequency with which the net short position is disclosed. The recent change from monthly to bi-monthly is an improvement however it is not sufficient to balance the interests of large well-connected firms and market makers and individual investors.
With the advance of computer technology I find it hard to believe it would be difficult for brokerage firms to compile the total short positions held on a DAILY basis. This information would allow individual investors to better assess if a decline in price for a particular day was attributed to large increases in the short position. Likewise on days when the price rose dramatically investors could assess if the short position increased or decreased that day.
It is hard to argue that giving ALL investors access to more information is a bad thing. I believe the cost to firms to provide this information would be reasonable (no change is free obviously) and would provide far more value to the quality of our markets.
In addition, I do believe the SEC enforcement of naked shorting should be applied to all securities, not just a few favored entities.
Thank you for consideration of my recommendation.