Oct. 30, 2022
My short comments on the Proposed Rule: The Commission should require DAILY public disclosure of short positions. The Dodd-Frank Section 929X states that the Commission must require the reporting of short selling - at a minimum - once a month. I believe that the Commission should NOT just do the bare minimum; as the Proposed Rule 10c-1 introduces intraday reporting on securities lending, the Proposed Rule 13f-2 can likewise require the daily reporting of short selling. As an international investor, I have been especially disappointed with the lax regulation of short positions in the US market, so I applaud the SEC for the Proposed Rule, however I believe it must be amended with one very specific item in order to be effective. ETFs must be included in the reporting of short positions, since they can be used to circumvent regulations by synthetically shorting vulnerable stocks. I recommend the Proposed Rule be amended with these two points.