Oct. 12, 2022
October 12, 2022 Dear SEC, I work in the fields of automotive and information technology with a young family of four and invest in the stock market as a hedge for dwindling salaries in an environment of terrifying inflation and foretelling producer price indices. I am definitely not an expert in the stock market, but its my passion. Some of the recent events in the market show cracks in the concept of a fair and regulated market with natural price discovery. Market transparency is one of the most important goods to enable price discovery and a fair market. It cannot be, that realtime data about market- and limit-orders is traded between market makers and payment-for-order-flow brokers for full transparency about retail activity within milliseconds, but security loans or short selling stays hidden within aggregates and due to flimsy excuses about technical challenges and increased reporting efforts. It seems like, if the rules benefit the financial institution, the technical challenges are a non-issue. The use of open-source software and open-data usually leads to reliable, secure and peer-reviewed results. Make use of crowd-sourcing and leverage the diverse experience and knowledge of the masses. Do not allow self reporting or no reporting at all, as this leads to criminal abuse, and disables price discovery. This will obviously penalize retail investors and therefore the most reliable income of taxes to the states. Retail doesn't pay license fees to sub companies in tax havens and isn't able to reduce taxable profit with expenses. I am not a supporter of short selling in general. The stock market is a way to invest into and provide liquidity to companies. If I don't like a company, I stay away from its stock. But as short selling is an established part of the market structure today, make at least sure it is properly regulated and reported upon. Complex and untracked lending chains behind a single locate have proven to lead into economic fragility or a full-blown collateral crisis. If short selling could be reduced in any way, retail would benefit from reduced volatility and therefore less risks in the market. The pump dumps on the OTC markets, bear raids and short squeezes are undesirable phenomena and usually techniques used to fleece retail investors. I am for a transaction-by-transaction reporting including realtime intraday reporting requirements. 30 days, 15 minutes, any kind of delay will lead to abusive use of loopholes. If 15 minutes is the only choice available, then so be it. Please also assure that fines related to loans or fails to report are not a cost-of-doing-business but a punishment (e.g. a percentage of EBITDA of the institution). Thank you for your patience reading my comment, a concerned investor from Germany.