February 19, 2022
The requirements for beneficial ownership reporting is not stringent enough. Modern technology has been in place for decades that can make reporting this data almost instantly.
There is no clear argument that these positions should not be reported in 1 day for every market participant.
Institutional investors should not be able to hide their position changes for up to 36 days. This just allows the insiders to trade before anyone else knows about the movement. Insider trading is rampant, and no amount of propaganda is going to convince me otherwise, because I have worked on and for Wall Street, and I have seen it with my own eyes.
Also, the deadline differences between institutional investors and passive investors, is unnecessary. There is no convincing argument that institutional investors should need more time than passive investors for these reporting s. It can be argued that institutional active investors who participate in the executive business should have MORE stringent reporting deadlines. The current paradigm is backwards as it is now.
None of these rules will be effective at accomplishing anything if they are not followed by the teeth of enforcement. Penalties should be swift and heavy. The world leading Market Reputation of the U.S.A. is hanging in the balance.