Subject: File No. S7-18-21
From: Lewis Schofield

January 5, 2022

The current state of affairs with regard to the ability of all financial institutions to work together to enable the manipulation of stock prices, while avoiding meaningful, effective sanctions is ludicrous.

As you know, just one of the ways the financial industry stacks the deck in its favour is by the practice of Short Selling. Though justifications for this are expounded, it is very rarely justified and very often extremely harmful to the companies chosen as the instruments for shorting. The already, immensely, rich and powerful institutions extract even more wealth from those least able to afford it.

Being able to bring down the share price and, by extension, raise it, at will, when they chose to stop shorting, gives them the power to move the price as they like with implications for the stock they hold but also allowing them to benefit in the derivative markets that they run.

Financial institutions' ability to borrow shares without transparency, with respect to the number that they are borrowing, at what cost and from whom, only serves to lend them greater power to exploit all other actors in the market.
Were the proposed rule changes to be introduced, this would be a welcome move towards a fairer market.