Subject: S7-18-21: WebForm Comments from Steven Ranney
From: Steven Ranney
Affiliation: Independent Researcher

Aug. 16, 2022



August 16, 2022

 Transaction-by-transaction reporting is necessary for transparency in our markets. Our markets should be clear and obvious to all parties involved I've seen some comments suggesting that \"retail\" level investors don't need these kinds of information. This is wrong. Retail needs transparency, if anything and reporting \"in the aggregate\" is not transparency.

I support the 15-minute reporting requirement. The cost and effort necessary to fulfill this requirement are justified to prevent fraud and hiding \"in the loopholes\" of too many different regulations. Fifteen minute reporting will also all victimized companies a greater ability to defend themselves against predatory organizations and individuals. \"Short-selling in the dark\" harms true competition and price discovery and the idea that only a handful of short-selling hedgefunds \"know best\" is shameful and can lead to unsuspecting companies driven in to the ground through the chase for higher returns.

Retail traders are ABSOLUTELY benefitted by this rule. We have a much better idea of the risks of our decisions when we can see who is targeting our companies. if funds are allowed to short \"in the dark,\" retail investors remain dangerously unaware of the risks we take on when purchasing securities. Why negate necessary information? If all parties have all of the information, doesn't that help to \"level the playing field?\" If anything, retail and the public acts as a first-line watchdog in monitoring short-selling data for securities fraud. This is a new phenomenon, made possible by social media, and is clearly beneficial to the SEC and other investors. If you allow \"reporting in the aggregate\" and don't require a 15-minute reporting requirement, there are simply more dark corners in which to hide for fraudulent institutions.

Long, untracked lending chains can be inherently dangerous, leading to economic fragility. Securities lending activity can hide massively destructive chains of obligations that can even be a threat to national security and transparency in this area is more important that it has ever been.