March 14, 2022
This rule is a step in the right direction towards the goal of more fair and open markets and as a retail investor it would be one more tool at our disposal.
However, I worry that it has potential for abuse just like other self-reported forms for which there is massive precedent as evidence by fines issued by FINRA. These are considered \"mistakes\" and the managers are given such a small slap on the wrist that there is little point to being truthful on these forms.
I believe it should be the duty of exchanges and broker-dealers themselves to automatically report these positions on a much more frequent basis than every calendar month.
With all that said I still would like to reiterate that I'd rather have this proposal implemented in its current form than not implemented at all.