March 12, 2022
I appreciate all of the proposed rules in this document being written and 100% support more transparency in the execution of short sales. Unfortunately, unless requirements for real time auditing are added to this rule and those in violation are held accountable with substantial fines that far exceed their profit, then these rules are not going to accomplish the goal of short sale market transparency. This document needs to be rewritten to add said changes in order to fulfill their obligation to Congress mandate under Dodd-Frank to prescribe rules to make certain short sale data publicly available. I would attest that without real time audits and consequences for short sellers in violation of Reg SHO, a lack of accountability will open the door for skewed data being provided to the public. The public has a right to see short sale data that is factual and accurate, and the SEC has an obligation to ensure short sellers provide it to them.