Oct. 13, 2023
How is an SRO held accountable to themselves and if they make a mistake, they report only to themselves. I'm not sure how this can be considered to be just, how can we have this verified by a 3rd party that will provide visibility to the general investing public not just to the SEC, FINRA AKA good ole boys club. We should eliminate SRO's in our markets. I support the following from a previous post below. Short selling to me serves absolutely no purpose in the markets. If you think a company is going to go bankrupt don't invest in that company, you should not be allowed to actively bet against a company. Partially because short selling can lead to insiders actively sabotaging companies. There have been numerous companies in the past and present that have a hard time getting money from stock sales due to being actively shorted even though they are perfectly fine companies. If the company is truly bad then natural price discovery will show that. However, since short selling is unlikely to ever be banned this rule is important and needs changes before it can be allowed to pass. First off the commission should require daily public disclosure of short positions. The Commission should not do the bare minimum. Section 929X of Dodd-Frank states that the Commission must require reporting of short selling activity once per month AT A MINIMUM. The Commission must not do the bare minimum. Proposed Rule 10c-1 requires intraday reporting of lending. Proposed Rule 13f-2 can require daily reporting of short selling. As another comment for this rule stated: \"We often lament the fact that regulators in other jurisdictions have done more, moved further, and advanced the cause of transparency far more significantly than we have in the US. As other commentators have noted, the EU adopted a short sale reporting regime that essentially requires immediate public disclosure of large short positions, by individual issuers. Despite this onerous disclosure regime that goes much further than the Proposal, we agree that a study of the impact of the EUs regulation finds no evidence that the disclosure requirements have resulted in increased coordination or have resulted in short sellers being targeted for short squeezes.The concerns from the industry and from the short selling community are simply not valid.\" You don't need to reinvent the wheel, take notes from what other countries are doing. Additionally, ETFs must be included in the rule because they can be used to synthetically short vulnerable stocks and circumvent regulations. The SEC can do way more and far better in regards to short selling data. This proposed rule simply isn't enough and will change far to little from the current short selling status quo. The market badly needs stricter and more short selling requirements and the aforementioned changes will help with that. Please do the right thing and do not pass this rule in its current form. We want better, fairer, and more transparent markets and this rule in its current form doesn't do enough. Ruben