Subject: S7-18-21: WebForm Comments from CMD
From: CMD
Affiliation:

Aug. 16, 2022



August 16, 2022

 This proposed rule should be approved. I am aware that it may cost more for analytics/reporting, but that cost is a pittance compared to the hundreds of billions of dollars that market makers, hedge funds, and banks profit every quarter.
I am fully in support of this rule because short selling has proven itself to be the antithesis of a free market. If you do not have the gusto to outlaw it completely, like other countries, then at lease shine a bright light on it. Short selling enables collusion to destroy companies and has set back American progress by decades, and created a massive income disparity. Retail investors are getting fleeced by brokers that take their money, create the illusion that the investment is secure, and then turn around and lend shares out. This is the opposite of fiduciary duty. Their own investments are used against them?? If only the American people truly understood how systemically bad our markets are. It is unethical, though not criminal because, of course, the laws have been corrupted because of the inherent flaws with the self-regulating organizational model.

I explicitly support transaction-by-transaction reporting because it eliminates the ability to \"hide within the aggregate\" transparency means transparency and aggregates are not transparent.

I explicit support the 15-minute reporting requirement, saying the cost and effort are justified to prevent fraud and prevent hiding in loopholes.

I explicitly say that victimized companies need a greater ability to defend themselves against predators, and that \"short selling in the dark\" harms true competition and price discovery. The idea that a small number of short-selling funds \"know best\" and can hammer unsuspecting companies in the dark is shameful.

I believe retail will benefit from increased transparency. We have a much better idea of the risks of our decisions and transactions if we can see who is targeted which companies. If funds are allowed to short in the dark, retail investors remain dangerously unaware of the risks they take on when purchasing securities.

I believe it is a very desirable phenomenon of the public serving as first-line watchdogs in monitoring short selling data for securities fraud, strengthening the SEC and better enabling it to fulfill its mandate, at no cost.

I believe in fully funding the SEC, and changing the governance model to root out the over-influence of billionaires and stop the fleecing of ordinary Americans.

Thank you for your time.