Subject: File No. S7-08-22
From: Brian

March 25, 2022

Currently, institutional long investors must report their positions. This has been true for many many years.

Institutional short sellers have long argued that reporting their position would undermine their strategy.

This disparity is outrageous.
The fact that it has continued for so long is more than suspicious, it might actually be criminal.

If a short position is vulnerable to transparency, then they are not betting that the security price will drop due to market fundamentals, are they?

If a short position holder is able to become so over leveraged with borrowed money that it threatens market stability, and bank solvency... well, let's just say that is not a behavior that needs to be protected.

The argument that \"shorters help the market\" is a fallacy that has stood unchallenged for too long.

The truth is that institutional shorters utilize options and dark pools to undercut a security's price. Add to that the fact that the regulatory framework around borrows and locates is a 'bad comedy joke' and, well, we've the foxes in the hen house for a long time now. So long, we've forgotten what it means to protect our hens (in this case, the 'hens' are American corporations.)