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

Oct. 31, 2022



October 31, 2022

 I firmly believe that the SEC must take a hard stance against institutional Short selling rules, regulations, transparency of reported data and furthermore, enforcing infractions of these rules in a way that dissuade any further abuse.

Short Sellers are not investors. Through all of my studies I have yet to fully wrap my head around the true value short selling beings to market integrity and the betterment of the American economy. They are strictly there for profit, which creates an environment where unscrupulous activity outside of the markets can take place to better their bet against a company/fund. Because short sellers are not investors, their rights and influence within the markets must be strictly monitored, even policed, and it is the SECs duty to keep a watchful eye on their activities, which can only be done through increased transparency of their holdings/positions and obligations.

Short selling also is the reason for the entire \"meme stock\" craze that injected an enormous amount of volatility into our markets. With true transparency, events like the Jan. 2021 short squeeze can become fewer or nonexistent. The level of stress that event brought into our markets was nearly unimaginable and, in my opinion, the whole reason the unprecedented event of removing the buy function was removed from so many \"brokerages\".

To sum up, I am asking the commission to require daily public disclosure of short positions by pushing Proposed Rule 13f-2, AND include ETFs in the rule because they can be used to synthetically short vulnerable stocks and circumvent regulations.