Oct. 18, 2022
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. 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 The outdated past requirements off bimonthly is insufficient in the current marketplace.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 Sent from Mail for Windows