Subject: File No. S7-18-21
From: Anonymous

February 20, 2022

In my lay opinion, u/gherkinit on Reddit has provided evidence that ETF share creation eg XRT at 1300% short interest and reg sho inclusion 12-2021 is being used to hide short interest in GME. GME experiences volatile price moves consistently 35 calendar days, 6 trading days for active participants, then t+2 settlement days after CME futures expiries. For example 11-4-21 price action after 9-17-21 expiry. Thousands of retail investors are aware and have 0 faith in the sec and doj to act.
This seems a national security threat to me as rational investors without access to insider information would seemingly want to divest from US securities markets knowing stocks can be nakedly shorted ad infinitum via ETF share creation as has been demonstrated by academics.

Market maker bona fide liquidity operations serve no useful purpose for price discovery in a free market either. Short interest hiding in options is extremely obvious in quarterly runs eg 5-24, 8-24, 2-24, and 11-24 2021. Theorized futures swaps, variance and entropy swaps or isda contracts are not visible to retail. Any short interest obfuscation should be reported. Shares should be given unique id and tracked to document rehypothecation, locate for borrow, and ETF creation abuse.

Papers:
https://www.google.com/url?q=https://jacobslevycenter.wharton.upenn.edu/wp-content/uploads/2018/08/ETF-Short-Interest-and-Failures-to-Deliver.pdfsa=Uved=2ahUKEwilhYG-2Y32AhVfIDQIHepfBNoQFnoECAgQAgusg=AOvVaw2WVg01drWUMaAS_rvs5CZJ

https://www.reddit.com/r/Superstonk/comments/qvyjap/moass_the_trilogy_book_one/

T+1/t+0 would allow retail to make these things more clear, especially with dark pool/otc purchases in t+3 premarket. These tactics may be legal to the letter of the law but aren't in spirit and threaten in my opinion social stability in that millions have learned of effective government support via inaction for naked shorting via FTDs, seeming broker market maker collusion in the case of communication 1-28-21.