Subject: S7-08-22: WebForm Comments from Ross Brown
From: Ross Brown
Affiliation: SVP, NA Cloud Partners and Services

Oct. 09, 2022



October 9, 2022

 Transparency leads to efficient markets and price discovery with current trading systems the accurate and timely reporting of positions is already available as a data set, but not reported in a way to aid price discovery.

Given this data already exists in market maker transaction systems and there is no technical or significant labor burden to automate the reporting of these positions and given the SEC commitment to transparent markets, there really isnt a legitimate market interest in allowing this to stay hidden.

The argument for allowing this to remain hidden can only be to protect market actors ability to manipulate other investors through partial and incomplete trading data.

The value of this data to market effectiveness is clear and the burden to produce it is extremely low.