Aug. 16, 2022
August 16, 2022 First, as a retail trader please understand that my comment seeks not only to address the proposed reporting requirements, but also the comments made my large organizations citing impacts on retail traders. Most importantly, I vehemently support transaction-by-transaction reporting. Current aggregate and delayed reporting enables institutions to shuffle trades and \"hide within the aggregate.\" This proposal seeks transparency, and aggregates are not transparent. In reference to delayed reporting, I also heavily support the 15-minute reporting requirement. Several institutions have commented that there is incremental cost and effort to make this happen. Being a part of a larger corporation myself, I fully understand the reference to additional cost and effort. That being said, I believe the resources are more than justified to create transparent markets, prevent fraud, and remove loopholes currently being used to hide information. Several institutions' comments explicitly call out removal of short sales from the proposal. This is particularly egregious and further points to predatory practices being hidden by larger organizations. Short sales must remain within the reporting requirements. 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 number of short-selling funds \"know best\" is preposterous, and their ability to attack companies in the dark needs to be brought to the light. I mentioned earlier that I am a retail trader. It has become apparent to me that the rules for retail traders and for larger institutions are not the same. In fact, it's apparent that many larger players bend the rules and feel above the integrity required in fair markets. With heavy competition with each other and a lack of real punishment for transgressions (tiny fines mean nothing), even those organizations attempting to play fair have little incentive to do so or they'll simply be outcompeted by playing unfairly. We must uphold a fair, transparent market not only for the retail trader, but even moreso for the integrity of larger players. If funds are allowed to act in the shadows, retail investors remain dangerously unaware of the risks they take on when purchasing securities and a number of funds will be encouraged to act dishonestly. Finally, unchecked lending practices, have been at the center of economic fragility for several decades. Securities lending activity can hide incredibly destructive practices that are essentially a threat to national security. I can't stress it enough: the transparency proposed by these reporting requirements is the high standard we need and is more important than it has ever been.