Subject: Re: Release No. 34–94313; File No. S7–08–22 Short Position and Short Activity Reporting by Institutional Investment Managers
From: Lee R. Jastram
Affiliation:

Oct. 18, 2022

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October 18, 2022
 
Vanessa A. Countryman
Secretary
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 205499–1090
rule-comments@sec.gov
 
Re: Release No. 34–94313; File No. S7–08–22 Short Position and Short Activity Reporting by Institutional Investment Managers
 
Ms. Countryman:
 
Short sale reporting requirements needs  updating to keep up with real world activities in the markets. The outdated past requirements off bimonthly is insufficient in the current marketplace. Through Etf’s and derivatives abusive naked shorting is robbing investors intraday and intraday. Others as well as I believe that establishing something similar to the European models of combating abusive shorts that at least daily reporting of short positions by institutions or large orders shall be on record. Broker dealers and lenders etc need to prove they can deliver shares  to short and not give a trust me bro I can cover you for a share locate. With the SEC’s ethical obligations to the orderly and efficiency of the markets and regulatory obligations charged to the SEC by congress there needs to be more done than the bare minimum per section 929x of the dodd frank act. There is still confidence the SEC if they so choose to can  right the ship in these  market waters with rampant bad participants in shorting, off exchange trading robbing price discover and seemingly infinite failure to delivers. Updating and improving the short sale reporting and activity would be a great start, Thank You.
 
Lee R. Jastram
LRJ Holdings llc

 
 
 
 
 
 
 
 
 
 
 
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