Oct. 30, 2022
October 30, 2022 Commenting on File No. S7-08-22 Short Position and Short Activity Reporting by Institutional Investment Managers I support this proposal and anything that will result in increased transparency, a more free and fair market, and protection of investors (especially retail investors). While I support this I still feel it is too lenient. In particular I think it is ABSOLUTELY ESSENTIAL that synthetic shorting via ETFS (whether group \"basket\" ETFs or the confusing and pointless new \"single stock\" ETFS) are also included in the reporting and transparency. While I want this proposal to pass I must again reiterate that I feel it is ABSOLUTELY ESSENTIAL that ETFS (of any kind) are included in this proposal I also have to confess I'm confused and annoyed that reporting is only being required to occur once a month Thats absurd. In the proposal \"File No. S7-18-21 Proposed Rule: Reporting of Securities Loans\" it is being proposed for a 15 minute daily reporting time of securities lending. If that reporting requirement can be down to a 15 minute window there is NO EXCUSE for short activity reporting to be a once a month window. The limit should be 15 minutes here as well. Not a month But, with the digital age we live in even 15 minutes seems far too generous. 5 to 10 minutes at the most in my opinion. Honestly, it should be intant real time, but I'll take whatever fairness I can get in this corrupt world. If it TRULY is impossible to have a 15 minute reporting time then daily should be the absolute limit. A month is just an insane amount of time in an algorithm and AI run market. Once again... ETFs absolutely MUST be required to be reported on in this proposal. There is too much risk currently with the allowance of shorting via ETFs for it to not be covered by this proposal PUBLICLY reported. In further regards to data completion, accuracy, and reporting times There is ZERO reason, NONE AT ALL, that any data for ANY activity performed in the markets, CAN'T or SHOULDN'T be provided, not just \"same day\