Subject: S7-08-22: WebForm Comments from Alexander Wolfsjager
From: Alexander Wolfsjager
Affiliation: Baker

Oct. 31, 2022



October 31, 2022

 Suppport for transparency and public disclosure of short data.

Total securities on loan on any given day is about $1.5 Trillion USD - yet that gigantic market remains largely de-regulated.

If funds are allowed to short in the dark, retail investors remain dangerously unaware of the risks they take on when purchasing securities.

The SEC repeatedly admitted that its very difficult to trace
or prove activities like illegal naked short selling(short of a whistleblower like Tobin Mulshine in Gaming Wall Street, due to the lack of reporting requirements and regulatory oversight.

Regulators would need to make some of that information publicly available,
both on individual transactions and aggregate information.

Secret short selling hurts individual investors in the name of greater profits for hedge funds. Is that what the public would want from its government? Short selling has serious consequences.

Learning from 2008: Lack of transparency can lead to systemic risk

ETFs must be included in the rule because they can be used to synthetically short vulnerable stocks and circumvent regulations.