Subject: Comment Letter for File Number S7-08-22 Short Position and Short Activity Reporting by Institutional Investment Managers
From: Concerned investor
Affiliation:

Oct. 29, 2022

 


There is an overwhelming need for transparency and this rule falls massively short.  There are participants in the market that provide inaccurate information to the retail community regardless of it being a purchased set of data or a set of data that was free. The lag in reporting is just one piece of the puzzle. For starters the report of a position should be publicly available and reported within an  hr of the position opening.  Shorts are not utilizing shares that they own and all beneficial owners being taken advantage of should have all information available to understand exactly how their Investment is and will be impacted due to the back door relationships between BROKERS and participants.
 
Recommendation:  public  database updated 2 times per day. Pre market reporting of positions and AH as well. There should also be full transparency across the board meaning positions, names, etc. are reported. There is no reason to allow a short seller to hide their position or  entity when they continue to state that short selling is something that is positive for the market. ALL positions should be reported daily. If new positions are opened after one reporting time frame, there should be intra day updates provided. There is no reason what so ever this data should not be available to the public. ACCURATE DATA.
 
Second Recommendation: Create a specific formulate to calculate short interest and hold parties  accountable.  There should never be waiving of margin requirements when a Short seller gets caught under the gun.
 
LASTLY -  ALL TYPES OF SWAPS SHOULD BE REPORTED TOO. If you do   not provide  all of the data to retail for free, you are continuing to allow WS to conduct predatory practices. 
 
NO DATA SHOULD BE HIDDEN IN A FREE MARKET and  it should be  kept up to date on a  daily basis. If our current system  in place cannot support this, the system is failing everyone and the  regulators remain a party too until proven otherwise. 
 
-Concerned investor
 
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