Subject: S7-18-21: WebForm Comments from Nicholas Harris
From: Nicholas Harris
Affiliation:

Aug. 16, 2022



August 16, 2022

 A transaction-by-transaction reporting requirement is important as it prevents hiding things within the aggregate. Aggregates are not transparent enough and do not provide enough transparency. Transaction-by-transaction reporting provides far greater transparency than aggregates.

A 15 minute reporting requirement is critical in this day and age when high frequency traders and other market manipulators are involved. If trades can execute thousands of times a second, why can they not be reported within 15? To assume the cost is too great is ridiculous as a 15 minute reporting requirement also would help prevent fraud and rule breaking.


Companies that are victims of short selling need a greater ability to defend themselves. Short selling in the dark is a black eye on American markets and a parasite of human progress.  Investors will benefit greatly from full transparency, it will provide us with greater information with which to
assess risk. If large funds are allowed to short in the dark, retail investors are dangerously unaware of the risks they take on when purchasing securities.

A great number of retail investors have emerged with the knowledge and diligence to review any and all data provided to aid with complaints, tips and ultimately enforcement. More transparency and data is always valuable, there is a reason large funds resist and spend so much money to fight these changes.

Securities lending chains are dangerous and pose a major risk to many institutions. Transparency is more important than it has ever been.