Subject: S7-08-22: WebForm Comments from Thomas S.
From: Thomas S.
Affiliation:

Oct. 30, 2022



October 30, 2022

 Dear Commission,

I support this proposal since every added transparency is improving the fair market and moving it closer to the definition of a perfect market. A more perfect market would reduce fraud and improve price discovery.
Short selling of stocks has huge and serious consequences especially for small companies. Multiple reports or interviews which hedgefund managers show that the ideal scenario is shorting a company into the ground so that the shorts never have to be closed and the profit is maximized. Because of this short selling has to be regulated more and transparency is key, to enable investors to make educated decisions.
This means the short selling should be reported to the public in a high frequency as possible. Intradaily reporting would be the best and the data should exists, since it is already in the systems of the companies which do the shorting. And they shouldn't be scared of providing this data, since if it is based on strong fundamentals it shouldn't matter if it known by the public or not. So at least a daily reporting should be required, but like mentioned a higher frequency would be even better
Furthermore this should not just include stocks, but it should also include ETFs. This is even more important since it is now possible to create new ETFs with a small amount of stocks in it. If the proposal is not extended to ETFs it would be easy to evade by just creating an ETF with the stock one wants to short. So it is very important that it gets extended to include all possibilities.

Best Regards
Thomas S.