Subject: S7-08-22: WebForm Comments from Joshua Hudson
From: Joshua Hudson
Affiliation:

Oct. 07, 2022



October 7, 2022

 You have a problem. The regulations on short selling are not being enforced and naked short selling runs rampant in the market.

The time is come where the true net short position must be published for all securities and should that position exceed 100% (note this won't happen with the DTCC's rules because they use the wrong calculation on purpose) it's time to investigate. The net short position is (number of shares sold short) / (number of shares outstanding).

While it is possible to exceed 100% short without naked short selling, it is difficult and an investigation will almost certainly find the crime of market manipulation anyway.