Subject: S7-18-21: WebForm Comments from Phil Duvall
From: Phil Duvall
Affiliation: Data Scientist

Aug. 16, 2022



August 16, 2022

 Passing this rule as-is is essential for bringing integrity back into the market. Transaction-by-transaction reporting eliminates the ability for large funds to hide their trading practices within the aggregate - transparency is essential. The 15-minute reporting requirement is CRUCIAL for preventing fraud and unethical trading practices, which unfortunately have become commonplace in large hedge funds. Reporting on a 15-minute basis is truly simple to automate, and the data scientists who work for firms will have no problem adopting these practices immediately. In this market, companies are victimized by those who parasitically short sell stocks in the dark. We need accountability for companies who chose this malicious practice, as well as transparency on untracked securities lending.
Retail investors will unquestionably benefit from increased transparency, as traders will be better equipped to understand the risks of their decisions. We are emerging into an age of transparency, where the public can hold large corporations accountable when their actions are viewable. This 15-minute rule is a major step forward towards this brighter, more accountable future. Thank you for the challenging yet ethical decision to bring transparency to this critical issue that is foundational to the thriving of the American people.