Aug. 16, 2022
August 16, 2022 I explicitly 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 requirement because 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, and short selling in the dark harms true competition and price discovery. The thought that a small number of short-selling funds might know best and could harm unaware companies in the dark is shameful. Retail will benefit from increased transparency by having a much better idea of the risks of their decisions and transactions if they 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. The public could serve 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, can lead to economic fragility. 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 than it has ever been in this day and age. Thank you for taking the time to read my comments. I hope we all may have a clear and fair financial future ahead of us. -DJM.