Subject: S7-08-22
From: Zachary Budinski
Affiliation:

Apr. 26, 2022

Hello, 


I am a primarily OTC investor. 


I think the amont of short selling, naked or known, is abhorrent. The whole reason of SEC 15c2-11 was to prevent the OTC market from being a casino. Yet, it is still a market where the house always win. 


Increasing retail knowledge of short interest or positions can only be beneficial. 


I also think the 2.50 rule is counter-intuitive and damages retail through un-informative shorting. 


The quotes from the article above from: 


https://www.sec.gov/files/White_OutcomesOTCinvesting.pdf 



point to exactly how most of retail feel the OTC market is manipulated. 


I also think it's hurtful to not allow Retail to short OTC for the reasons: 


A) shorting induces liquidity 
B) incite initiative to "Squeeze" retail shorting behaviour 
C) retail knows fundamental value of OTC stocks better 
D) reduce occurrence of "Pump and Dumps" as retail shorting would do it more aggressively off fundamentals 


Thanks