Subject: S7-18-21: WebForm Comments from Jonathan Patterson
From: Jonathan Patterson
Affiliation:

Aug. 16, 2022



August 16, 2022

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

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

3.  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.

4.  We currently live in a time where average citizens/concerned investors are doing a lot of the watchdog work by monitoring short selling data for securities fraud which is beneficial for the SEC and their mandate.

5.  There are inherent dangers in long, untracked lending chains, that can lead to economic fragility. Securities lending activity can hide massively destructive chains of obligation that can even be a threat to national security, and so transparency in this area is more important than it has ever been.