Subject: S7-18-21: WebForm Comments from Ryan Grimes
From: Ryan Grimes
Affiliation:

Aug. 16, 2022



August 16, 2022

 They need to be held accountable and have to follow the same rules we all follow. Do you really want to support a world where things keep getting more unfair for everyone besides the 1%? People literally kill themselves over short selling... to let this rule go into effect to protect Citadel and friends would be to end the American dream in its fullest capacity. I'm only 32, but I've lived through 2008, 2020, and soon 2022, the worst crash in history because of bent wall street rules that only favor the rich. You should want transparent information so everyone has an equal chance to win. It's 2022, not 1970... everyone deserves an equal chance to win and be heard. I very much support transaction-by-transaction reporting because it eliminates the ability to \"hide within the aggregate\" transparency means transparency and aggregates are not transparent. I also support the 15 minute reporting rule, as such the cost and effort are justified to prevent fraud and prevent hiding in loopho
 les. Victimized companies need a greater ability to defend themselves against predators, and \"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. 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. The new and 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. The dangers inherent in long, untracked lending chains, that can lead to economic fragility. Securities lending activity can hide massively destructive chains of obligati
 on that can even be a threat to national security, and so transparency in this area is more important than it has ever been. Fraud can be hidden in aggregates, and intraday fast-paced manipulation cannot be uncovered with T+1 alone. Things move very fast and crashes happen very fast. Granting all market participants a high-resolution view into short selling would allow them/us to see and then get out of the way when there is an approaching train. It would protect retail investors against sophisticated strategies by well-capitalism and dominant, predatory funds. It would allow everyone, especially regulators and law enforcement, to detect more sophisticated fraudulent activity (eg we could examine activity around short and distort attacks at a high resolution).

The DOJ has recently focused on exactly this type of fraud, and empowering law enforcement is a prime benefit of transaction-by-transaction, high temporal resolution reporting. Retail investors deserve to be fully informed of the risks they are taking on when they purchase securities. The Chair Gary Gensler has highlighted that specific point many times. It is the SECs core mission to protect retail investors. It is time for them to be consistent with that mission, even if big funds complain about cost and inconvenience. Integrity is not free. Market integrity is not free. A truly free market does not happen without effort and inconvenience.

People have literally killed themselves as a result of short attacks. Allowing them at least the chance to see the danger they are stepping into is one of the most important things the Commission can do.

The solution to retail stepping into danger is not a few stupid videos. It is NOT a public relations problem, it is a policy problem. This rule, as written, is a strong protection for investors against the dangers of predatory selling and pump and dump schemes. It allows us to examine who published what and how short selling activity behaved around those publications.

Thank you for considering my opinion and upholding the right values for the future of America, my generation, the generations before mine, and the generations after mine.