Oct. 25, 2022
October 25, 2022 To whom it may concern, This rule proposal should be improved in the following ways: First al short sale data should be as transparent and detailed as possible. In this day and age requiring specific details of how short sales are preformed is important and realistic. It is also vital to fairness in our markets. All market participants should be required to provide data on their short sales. It is essential that requirements be put in place to ensure buy to close actions(for FTD) are taken appropriately. Systemic risk will occur if unbridled and unreported buy to cover occurs. Simply put, there is no situation outside of Wall St where a fail to deliver would ever be tolerated. If a fully paid for security fails to deliver, there must be a hard requirement to buy-in and close that transaction. This is clearly within the regulatory power and scope of the SEC, who in the midst of the 2008 crisis issued new (interim) rules against abusive naked short selling primarily to protect troubled financial institutions. See 2008-204 SEC Issues New Rules to Protect Investors Against Naked Short Selling Abuses (Sept 17, 2008). Similar rules should be the norm. Enforce stock borrowing requirement in addition to reporting reliance on bona fide market making exception. No party should be allowed to neglect or avoid REG SHO requirements. Thank you for your consideration of these comments.