Subject: "Comment Letter for File Number S7-08-22 Short Position and Short Activity Reporting by Institutional Investment Managers"
From: Stephen Lee
Affiliation:

Oct. 17, 2022

 


The SEC has proposed a new rule, 13f-2, to provide disclosure and transparency around short positions being held by investment managers. They recently re-opened the comment file for this rule for 2 weeks. We The Investors will be filing a comment letter on this rule and encourage our supporters to do so as well. 
I honestly cannot believe this is even being debated. As an investment manager and advisor for over 18 yrs I am dumbfounded about why transparency is being fought so much by big investment managers that "short" stocks.  I am a big proponent of shorting because it weeds out the badly managed companies in the market. However, I have also seen numerous cases where companies are forced to bankruptcy by abusive shorting practices.  In my opinion, synthethic shorts via swaps, borrowed shares should be reported. Real-time settlement is needed and would solve many of the abusive "floating" practices that occur from Prime lending out shares they cannot locate to borrow.   
  
Faith and Trust are being lost and have been lost in the financial and political systems. This is just a simple reporting requirement that NEEDS to be enacted. If these managers are not doing anything wrong then why are they fighting this?  


Stephen