Subject: S7-18-21: WebForm Comments from Otto Keppke Lopes
From: Otto Keppke Lopes
Affiliation: Cook

Aug. 16, 2022



August 16, 2022

 Transaction-by-transaction reporting must be enforced because it eliminates the ability to \"hide within the aggregate\" aggregates are not transparent and retail wants a transparent market.

15-minute reporting requirement must be enforced, the cost and effort are justified to prevent fraud and prevent hiding in loopholes.

Victimized companies need a greater ability to defend themselves against predators \"short selling in the dark\" harms true competition and price discovery. A small number of short-selling funds \"knowing best\" can hammer unsuspecting companies in the dark, that is shameful.

Fraud can be hidden in aggregates, and intraday fast-paced manipulation cannot be uncovered with T+1 alone. SEC must enforce very fast paced reporting on security loans so crime/fraud cannot be masked.

Retail will greatly benefit from more transparency as it allows retail to be not only more informed but correctly informed.

I think the best we can do is meet institutions in the middle somewhere. Instead of 15 minutes, every 17 minutes. No exclusions. And failure to report every 17 minutes will be penalized with a 10 million dollar fine for each instance. For every additional 5 minutes they are late reporting another 10 million dollar fine. Considering that institutions have no problem with high frequency trading, they shouldn't have any problem with high frequency reporting. That seems like a fair compromise.