Oct. 29, 2022
October 29th, 2022 Vanessa countryman, Secretary Securities and Exchange commission 100 F street, NE Washington, DC 20549-0609 Dear Secretary Countryman, I am writing in strong support of rule 13f-2, Short position and Short activity reporting by institutional investment managers" It is my understanding that FINRA requires short lending positions to be reported twice a month, which in today's high speed and automated market environment seems infrequent. When trades are made by the investors they are posted to all data sites immediately and held on brokerage records; wouldn't it be fair to say that short positions are still trades and should still be reported immediately after the purchase/sale? As a concerned investor, it seems rather unfair that my trades are available for anyone to see, while investors "buying a stock" using a shorting method only have to report it twice a month. This is what I believe overarches into other current market issues, the biggest being FTD,s, as institutions can short sell a very large number of stock and, instead of reporting the actual numbers, can just borrow lent out shares to roll over their FTD,s obligations leading to suppressed price discovery, as shares never actually hit the lit market. From this, it is my belief that the reporting of short activities should be a daily occurence to make sure the investors using this practice do not over leverage their positions and are fulfilling their obligations in buying back the borrowed shares. Sincerely, - A concerned investor