Mar. 15, 2022
Should a Manager also be required to include short positions resulting from derivatives in determining whether it meets the Reporting Thresholds? If so, explain why, and describe any associated costs and benefits to doing so. If not, explain why not. Yes they should include the short position. The short position should be included so that people are not shorting more stock than they can cover. It is important that firms have cash on hand to meet margin requirements. Investors and companies should also be aware of short interest in their investments. Should a Manager also be required to separately report its end of month gross short position in derivatives, including, for example, options? Please explain. Yes it is important to understand the total short position. Options allow firms to hide their short position through out of the money puts and calls. Short positions should be very transparent for all investors and companies to see. ETF creations and redemptions would be included under Proposed Rule 13f-2. Should ETF creations and redemptions be excluded from Proposed Rule 13f-2? If yes, describe why. If no, explain why not. Yes, ETFs should be included in reporting of short positions. ETFs are often invested in through pension and retirement funds. If an ETF is heavily shorted, then everyday people could lose their whole investment. It is also not fair that firms can hide their short position by investing in ETFs that they know are heavily invested in a company. The stock market should not be a shell game, if I am investing in a company, I should know I own the share of that company. Should Managers be required to consider short positions that the ETF holds in individual underlying equity securities that are part of the ETF basket in determining whether the Manager meets a Reporting Threshold for such underlying equity securities that are part of the ETF basket? If yes, explain why. If no, explain why not. Yes, ETFs should not provide a haven for managers to short stock. This makes it difficult and complicated to calculate the actual short position on a stock. Firms may be exposed, but because their short position is not reported clearly, there is no way to know that they are at risk. We should have clear data and information on short position. Is monthly reporting by Managers appropriate? If so, explain why. If no, explain why not and describe an alternative frequency of reporting that is more appropriate. No, Managers should report positions as soon as they are made. There should be a system for documenting all short positions with a clear view to retail investors. This platform should be simple and shown in real time. That way there is no way to cook the books. Is the Commission’s estimation that, over the course of a year, for every short position created by a “short” or “short exempt” sale order, there will be an equal and opposite number of “buy to cover” purchase orders placed in order to cover, and ultimately close out, those short positions, an accurate projection of how frequently “buy to cover” order marks will be used? If there is a more accurate means of estimating the volume of anticipated annual “buy to cover” order marks, please describe its structure and why it is more accurate. Managers should not be able to short a stock without being covered. Naked short selling is stealing from retail investors. How can I sell my car if I do not own the car? Managers are using their short positions to destroy companies and bankrupt them. This is rampant among big box stores. All short positions should be covered at the time of purchase. Managers should clearly indicate how they plan to cover their short position on a daily basis. Thanks!