Subject: S7-18-21: WebForm Comments from Steven Downs
From: Steven Downs
Affiliation:

Aug. 16, 2022



August 16, 2022

 I am tired of living in a world where those with all the money can just hide their shady dealings in aggregate reporting under the guise that they are being \"legitimate and fair\". I support the proposed transaction-by-transaction reporting as that will mean transparency in the markets. Furthermore, the 15 minute reporting requirement will help eradicate fraud and prevent hiding in loopholes. This requirement will fully justify the cost and effort needed to enforce.
The idea that a small number of short-selling funds \"know best\" and can completely dictate whether a victimized company will be made prey in the dark is shameful and not representative of a world I wish to live in. These victimized companies need a greater ability to defend themselves from these predators and \"short selling in the dark\" harms true competition and price  discovery.
Retail will benefit from increased transparency tenfold. We have a much better idea of the risks of our decisions and transactions if we can see who has 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.
On top of this, strengthing the SEC and better enabling it to fulfill its mandate at no extra cost is just an added benefit of the public serving as first-line watchdogs in monitoring short selling data for securities fraud.
The inherent dangers in long, untracked lending chains can lead to economic fragility unheard of outside dystopian sci-fi nightmares. 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 now than it has ever been.