Subject: S7-08-22: WebForm Comments from Brandon G
From: Brandon G
Affiliation:

Oct. 31, 2022



October 31, 2022

 Good Afternoon,

Thank you for taking the time to read my comments on the S7-08-22 proposal.

We need increased transparency in the markets. I am in favor of the rules and would like I would encourage the commission to provide the same level of disclosures for short positions that are currently done with long positions by adopting a policy such as the EU short sale reporting structure. We need to have all short exposure reported. There is no reason there should be loopholes for the elite to hide their exposure on a stock. We need to have better surveillance from the SEC to police the market makers who are using the market making exception to potentially abuse this in an effort to skirt compliance  with regulation SHO. It is not fair that a firm does not need to locate a share before selling a share short. When you do not locate a share to sell short you are effectively selling a share you do not own. The reason this is being done is so that you do not have to pay lending fees. This also allows them to have an advantage over people who require locating a share to short a stock
 . There should be no exceptions to shorting a stock a stock without locating the share to borrow as this should be present in a fair market.

We should also be working to make markets more fair to retail investors.
We also need to remove Payment for order flow transactions and ensure that retail trades do not go to dark pools. There is not reason that this should be happening this day and age. Internalized trading must be made illegal as it is not transparent. There should also be large penalties for breaking the rules which account for all profits made for breaking the rules and then some.
If an ordinary citizen stole a candy bar from the store they would have to pay for the candy bar, an attorney, a court date, jail time and fee 1000x the cost of the candy bar. If you steal money as an investment company or market maker you end up paying less than 1% of the profit that you made and can continue without any repercussions. If you do not increase the penalties that companies pay for breaking the rules companies break the rules on purpose and just chalk up the rule breaking to the cost of business. This hurts retail investors.


Thanks for you time, I know the The purpose of the SEC is to protect all investors and hope that the SEC will continue to adopt rules that work and contain the backbone to enforce all market participants to play on the same playing field.