Oct. 30, 2022
October 30, 2022 I support the need for increased transparency in Short Position and Short Activity Reporting by Institutional Investment Managers. Increased transparency is never a bad thing. I believe the Commission should seek to provide the same level of disclosures and transparency for short positions as is currently done with long positions via 13F filings. All short exposure must be included in reporting as well including the derivative exposure. The loophole which does not require this to be reported is a glaring hole that can be abused by larger entities. You can look at the recent use of this by Archegos. Even though they did not have anything reported, the derivative exposure they had caused a detrimental effect on the price of stocks. More transparency would have allowed other institutions to mitigate the effect of Archegos trading and the significant exposure that arose from such positions. ETF short positions also need to be monitored to fully understand the shorting of the market. Thank you for your time. As a concerned retail investor I appreciate the steps being taken by this office to bring more transparency to our financial institutions.