Oct. 30, 2022
The Commission should require daily public disclosure of short positions. Proposed rule 13f-2 does not do enough as is. Proposed rule 10c-1 requires daily reporting, so should 13f-2. Short selling has been another root cause of the market issues that seem to never be fixed. Naked short selling exists. This dilutes the share pools and can be used to push companies into bankruptcy. ETFs need to be included into proposed rule 13f-2. ETFs can be used to circumvent reporting of short sales of victimized companies. Proposed rule 13f-2 should be revised to include: 1. Daily reporting of short sales. 2. Inclusion of ETFs and all other financial instruments that can be shorted. Sincerely M. Valkoun