January 9, 2022
Dear Commission members, Commission, and Public
It seems absurd to me that we should be debating about a resolution by the Securities and Exchange Commission to make available to that commission, and public, data on Securities based Swaps. This is not an effort to prevent, or end illicit and illegal swaps, this is just a rule to make them transparent to the very institution that should have been watching these for decades. The importance of short selling in providing liquidity, both share and capital, as well as in stability of the system goes back to the very beginning of the London and NY stock exchanges. I respect the system that our ancestor's built, and I respect the sordid affair of maintaining this system throughout it's many years. But it's time for a change.
The first step to allowing this change, and to fixing the underlying problems of the current stock market, is to ensure that YOU, the regulators, are aware to the full scope of the stock market. Any attempts to move forward in creating and using a blockchain stock exchange would require converting current shares into their digital counterparts, and doing that with millions of more shares for nearly every stock would impinge upon this. Practically speaking, you are between a rock and a hard place, captured by a broken system, and unable to fix it because the true problems aren't even seen. I respect the value of short selling, it's role in Price Discovery, I don't like it, but at the end of the day I respect and work within the rules of the game. I ask that you ensure the other players do as well.
Delaying this rule, something many of my peer's comments illustrate a desire for, would further allow those of them to continue to break those rules, but also endanger the game. I would like to remind all parties that the situation that brought us all to the brink of collapse, was the meteoric rise in a handful of stocks that \"no one in their right mind would own\". All of us almost lost everything, because a bunch of idiots thought they should phantom short more shares of specific stocks than exist, let alone more than they could certainly borrow. They did this through Securities based Swaps, rather they \"created\" these shares through SBS's. This rule alone does not prevent a repeat risk, this rule alone does not stop the creation of phantom shares that allow manipulation and malfeasance of publicly traded stocks, this rule alone does not protect the world's economies from the overzealous might of a few bad eggs.
I thank you for your continued struggle in fixing the errors of our forbearers. I thank you for the work that all of you put in. I thank you for the strength of character shown in fighting against the corruption in our capital markets. And most importantly, I thank you for accepting that this madness cannot go on. I offer you my hope and optimism through the difficulties ahead, that we may leave behind a better world for those we bring into it.
Always,
Josef Grey