Oct. 15, 2022
October 15, 2022 Re Release No. 34-94313 File No. S7-08-22 Short Position and Short Activity Reporting by Institutional Investment Managers Dear SEC, I am writing with regards to the above proposal which outlines the bare minimum set out by the Dodd Frank Act for intervals on short reporting. It is with much dismay that the bare minimum is what is being put forward. Specifically, reporting on these positions in the timespan of 2-4 weeks. This is unacceptable, and needs a much shorter timeframe. The shorting of securities through ETF's is so rampant that it has overtaken long trading volume (see ticker $XRT) where short volume exceeds 100%. Given the large volumes, a delay in reporting allows a tremendous amount of time for swaps transactions to take place where the shorts are hidden and passed on to someone else, thus not reported. I propose a much more rampant reporting period. Immediately would be ideal, however within 10 minutes I think would be acceptable. This would allow a trail of these transactions to take place. There is too much to be lost in 2-4 weeks of reporting. This shorting is a poison to retail investors everywhere, and I encourage the SEC to accelerate any and all reporting timeframes. Sincerely, Dave Thomas