Subject: S7-18-21: WebForm Comments from Patrick Horrell
From: Patrick Horrell
Affiliation:

Aug. 16, 2022



August 16, 2022

 Transaction-by-transaction reporting eliminates the ability to \"hide within the aggregate.\" Thus the rule promotes transparency as aggregates are by nature not transparent.

Similarly, the 15 minute reporting requirement seems feasible and the cost is justified to prevent fraud.

Victimized companies, which are often dwarfed in size by large funds, lack the ability to defend themselves in the world of dark pools and loopholes. Retail has no window into this world and can unwittingly invest in a copy earmarked for destruction not by price discovery but by predatory tactics of a select few large funds.

Retail, and individual investors generally, deserve to be protected by their government and transparency serves this goal. The public has proven itself sophisticated and interested in the type of data to be reported under this new regime.

There is danger in long, untracked lending chains and the systemic risk is borne by everyone. Let everyone share in the data and be adequately apprized of what, exactly, is going on.