Subject: S7-18-21: WebForm Comments from Martin Ruesges
From: Martin Ruesges
Affiliation:

Aug. 16, 2022



August 16, 2022

 I am a retail investor and I fully support transaction by transaction reporting. It is a step towards increased transparency and and protecting the interests of retail investors. In particular the benefits of increased transparency and accountability  derived from the 15-minute reporting requirement far outweigh any potential costs such a requirement would entail. The 15-minute interval is technically possible and practically feasible and it's costs pale in comparison to the benefits it would provide.

Companies victimized by predatory and sometimes naked short selling of their stock need a greater ability to defend themselves against predators, and \"short selling in the dark\" harms true competition and price discovery. To much can be hidden in the current agregate summary every two weeks. The idea that a small number of short-selling funds \"know best\" and can hammer unsuspecting companies in the dark is shameful. These companies are the backbone of the american economy.

Retail investors will also benefit from increased transparency. We have a much better idea of the risks of our decisions and transactions if we can see who is targeting 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. Unknowing retail investors who invest in these targeted companies can be seen as an added benefit of the practice of shorting in the dark, making it even more profitable. This is an insufferable state of things.

Lastly: Long, untracked lending chains, have the potential to lead to economic fragility. Securities lending activity can hide massively destructive chains of obligation that can even be a threat to national interests. They have the power to cause the next big economic crash and so transparency in this area is more important than it has ever been.

I as a retail investor am in full support of this rule. If anything it doesn't go far enough.

Sincerely

Martin R.