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

Oct. 27, 2022

 





All types of short exposure should be included in the disclosure requirements (i.e. short exposure via various derivatives such as options, all types of swaps, etc.). This is necessary to prevent market participants from exploiting loopholes in reporting. For example, some participants may ignore the disclosure requirements by transacting specifically via methods that don’t require disclosure.