July 21, 2020
This proposed rule change would undermine the credibility and integrity of the US securities markets. I have worked on the sell side of multiple Wall Street banks for nearly a decade now and seen the inside of how things work. Additionally I have served on in house counsel teams for many law firms with large Wall Street banks as their clients.
I worked directly on the trading floors at multiple institutions - this includes writing compliance manuals for Reg SHO and other related works on the "plumbing" of the US equities markets.
In my opinion this proposed rule should be immediately shelved. It is EXACTLY the smaller firms and institutions who should have heightened securities disclosures as they are more prone to the "pumps and dumps" that routinely affect the stock market.
This year we have seen feeding frenzies in poorly understood SPAC vehicles promoted by questionable characters while in prior years we have seen similar activity in Chinese VIEs. Many investors with little to no knowledge of the markets are being conned into losing their money.
If the SEC stands for integrity then please consider my plea.