Oct. 31, 2022
October 31, 2022 Vanessa A. Countryman Secretary U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 2054991090 rule-comments@sec.gov Re: Release No. 3494313 File No. S70822 Short Position and Short Activity Reporting by Institutional Investment Managers Ms. Countryman: The Commission must strive to go above the minimum requirements that are laid out in section 929X Dodd-Frank Act. The trend in the markets is towards greater volumes of trades and shorts. I feel that more transparency is key. Daily reporting or greater is the prudent reporting interval in the interest of transparency. This has been done successfully in the EU without any implosions of the market. Shorting presents systemic risk issues and therefore any efforts that can increase transparency should be undertaken to make such risks more apparent to the investors.