Oct. 17, 2022
October 17, 2022 Finances must be kept immaculately for the IRS and other auditors. There is also reason some of this information should remain private for a time. That said, there is no reason transactions shouldnt be sent to the SEC, like the CC in an e-mail, at the moment they occur. Please also allow some degree of corporate privacy, say with the exchanges to be netted weekly and published at noon market time the following Monday. While the delay in the rule seems within the law, it will have less effect than posting a 200mph speed limit downtown. Good rules have impact, this looks like a political stunt highly likely to get severe blowback from the community. Also, my accountant tells me two things: First, that were allowed to use what we believe a stock is worth as fair value on our assets. Im going to call this male bovine excrement and state that all positions should be reported at a market price within the reporting weeks highs and lows. This way, you cant value your Berkshire at $0.50 and your GenericPennyStock at $650,000. Please ensure the final reporting rule lists specific guidelines so that the reported positions are representative of market value. Second, that my open-source accounting software can auto-generate a document with this information. The burden of learning to do this and forwarding a file weekly ($200 for an exec to do it) shouldnt be too hard on someone able to pay $50,000/month just to be close to the NASDAQ trunk for latency reasons. I see no reason for the end of the month minimalist provisions. To truly be transparent, the SEC will need to put together a database of the total amount held short for each reported stock and update that periodically. My recommendation, again, is mid-market the Monday of the following week for company reports and around Thursday for database updates. This allows companies to keep a trading time edge and allows them to datamine for earlier info if they decide it is worthwhile. I think this commitment needs to be added to this rule, or, if out of scope, added separately later. As a former government administrator myself, thanks for taking the time to read this comment. My best times were when my reports were short and well-read, and my rules clear and effective. Hard to do in a political environment, but you will relish those successes someday.