Subject: File No. S7-08-22
From: Anonymous
Affiliation: Analyst who has been following frauds for 25 years

February 25, 2022

I think the proposal for publicly disclosing more information about short positions is a terrible idea. Unless you have done it, one will not understand how truly difficult short selling is - unlimited losses, public and private attacks, margin calls, etc. To add another layer so the longs can really attack shorts will push many short sellers to not short. And short sellers are the one check left in the market. Utimately with Gamestop the longs benefited from short sellers crowding in.

The auditors are incompetent and have sold out. When is the last time and auditor has caught a fraud?

The SEC doesn't seem to catch many frauds at all. Madoff comes to mind.

Much of the fraudulent information is often in the public filings. People that truly want to catch fraud can start there. That is where the short sellers shine. Doing the hard work and connecting the dots. They are like not-for-profit journalists because so few actually make money.

I have zero confidence that the SEC with additional information will be able to help anyone (Net) by this rule.

The SEC should start catching the many frauds in the US marketplace using public documents currently available.

A better idea:
I think the SEC (or someone else) should rank the number of frauds by Auditor to see which Auditor is the best to worst. It would essentially be a relative grade and with that information investors/companies can essentially kill the worst auditors.
This would be a public check on auditors to do the job they are paid to do rather than take money and catch almost nothing. The auditors today are like a security guard who is paid to catch criminals yet when a thief shows up takes a donut from the thief and looks the other way.