Mar. 14, 2022
Hello SEC, I am sending this comment with backup (attached). To start, every form of derivative and financial instrument that can be sold/package/exchanged/borrowed/swapped.. you get the idea.. anything that is "in-loo" of a share NEEDS to be accounted for in this short-interest data the rule is proposing to make available. You folks have not been aggressive enough. Next, the fact that when retail users buy securities on virtually any platform they are actually getting "beneficially" owned shares in street name is complete horse shit. Shares in this pool are not subject to supply and demand that virtually any other market would be subject to intrinsically and this is something that is assumed to be true in any "free market" that this ecosystem is claimed to be. Furthermore, the hassle to register shares directly is a pain in the royal ass. My broker is holding my TFSA shares hostage for $450 + 2 week to directly register (Questrade). That today is a couple months of savings for my household. Without doing this, our securities purchased by us are "lent" or used for multiple locations, even when our brokers tell us they are not. THIS NEEDS TO CHANGE!! Every single share that is issued by the company needs to be THE supply. This is the CONSTANT. Retail shares purchased by THE CONSUMER need to be only available to THE CONSUMER automatically. Not used in a pool. Not to be lent and then repurchased whenever the consumer retires. THIS IS FRAUD Use this rule to report ANY financial vehicle "in-loo" of a security, and add it to the short interest calculation against the constant. We have been waiting ever since we heard in January 2021 that there needs to be change. This is a follow up to my letter to Gary Gensler regarding "those events". Thank you