Subject: S7-18-21: WebForm Comments from Alex Miller
From: Alex Miller
Affiliation: Retail Investor

Aug. 16, 2022



August 16, 2022

 Hello,

I would like to start by commending the SEC for proposing rule changes that actually serve to benefit most investors. Some members of the financial industry have grown too comfortable after years of funding politicians and capturing insiders to work against the interests of the general public (see Hester Peirce and how all of her comments are inherently pro big money). These rule changes only get pushback from large financial institutions that stand to lose the veil of secrecy that allows them to conduct business in unethical ways.

Let's look at some of the large companies that asked for leniency in the rules Citadel Securities posts $7 billion in profit 2021, Fidelity reported $8.1 billion in profit, for the sixth consecutive record breaking year. The idea that prompt reporting is cost-prohibitive to firms that make almost more profit than the Environmental Protection Agency's annual budget during an ongoing climate catastrophe falls firmly in the \"I don't care\" category. Both of these institutions operate under the assumption that they'll rack up millions in fines over the years from illegal or unethical actions and that it's \"the cost of doing business\". Make prompt reporting the cost of doing business.

To be clear, I am in favor of 15-minute reporting requirements. In favor of transaction-by-transaction reporting. If there's no nefarious dealings, why hide it?
In strong favor of reporting short selling positions to better uncover discrete predatory attacks on companies. Large firms will argue that it is \"more difficult and costly if information regarding the trading strategy was publicly disclosed\", however I'd argue that with greater visibility we would see that some of these trading strategies are in fact, terrible strategies that only work because of lax regulations.

In fact, just for fun, let me propose a rule change to include a general short sale ban for two years with an optional permanent extension. This will allow companies who have been under aggressive short selling attacks to recuperate and potentially change course. Don't we want American companies to succeed? Why do we allow betting against our own economy?

Reading some of the previous comments I find it a hilarious comedy-joke that large institutions keep referencing \"protecting retail investors\" by allowing short selling to go unreported. Like seriously, who actually believes this? As a retail investor let me be perfectly clear the protection I need is greater transparency and enforcement.

Quite simply, if you require the cover of darkness to operate, you probably deal in illicit activities.

Thank you for your time and all your hard work.