Aug. 16, 2022
August 16, 2022 Please add transparency in the market. I fully support transaction-by-transaction reporting because it eliminates the ability to \"hide within the aggregate\" transparency means transparency and aggregates are not transparent. In my current profession, I work with data (eg. data mining, financial reporting, etc..) on a daily basis for the past 10 years. You need line item transactions in order to make informed decisions, and rolling up data on the aggregate level removes a layer of transparency and allows users to obscure/hide data. For any institution that invests using other peoples money (eg. pension plans), it should be mandatory to report specifically on all line item transactions. How else are you supposed to prevent fraud if you give hedge funds a black box to hide their trades in? I support the 15-minute reporting requirement - the cost and effort are justified to prevent fraud and prevent hiding in loopholes. Hedge funds already have the data and systems in place that collect this data. The costs are not as high as they say it is, and should be a cost of doing business similarly to how hedge funds get thousand dollar fines for committing million dollar fraud. The market should be fair and equal for all. How is it fair that companies that are targetted by short sellers (who create synthetic/fake shares) have little to no recourse to defend themselves? Victimized companies need a greater ability to defend themselves against predators, and that \"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. It's illegal for me to counterfeit dollar bills, why is it not illegal for institutions to counterfeit shares? The fact that these hedge funds want to hide their shorts is does not benefit anybody but themselves. If institutions want to partake in naked short selling, a practice banned in several other developed countries except USA, then institutions should have a requirement to report on it. Not doing so makes the public lose faith in both the SEC and the US financial markets when the rules are cat ered to only benefit the rich/large institutions instead of making it fair for ALL market participants 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. Making this information public will result in retail assisting the SEC in regulating institutions that take on too much risk when they target a company to short. Institutions will be discouraged from taking large risks, such as naked shorting companies due to the potential backlash from retail. This will create a safer, transparent, and removes systematic risks from the market. To summarize, the public will 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. Systematic risk is also reduced when long, untracked lending chains are allowed to persist that could 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. What's even worse is that large institutions will continue to take these risks because they know the federal reserve will bail them out using American taxpayer dollars which was evident during the 2008 crash, and during covid where trillions of dollars were funneled to these institutions. It is unamerican and not democratic to allow these large institutions take the american people hostage with unchecked bets/risky derivatives - adding transparency through these proposed changes will discourage these institutions from taking these bets in the future, and will benefit the american people through a reduced risk of financial collapse requiring the federal bai louts/handouts