Subject: S7-18-21: WebForm Comments from Ryan Moses
From: Ryan Moses
Affiliation: Retired business owner

Aug. 16, 2022

August 16, 2022

  This rule change is necessary to prevent predatory investment companies from hiding transactions within aggregates. The increased transparency will foster better confidence by retail investors in the competence of the SEC.

Any claims that 15-minute reporting would be prohibitively expensive, or otherwise unjustified, are deceptive.
Automated reporting is a fixed cost regardless of frequency. For predatory investment companies to state otherwise indicates how much benefit they receive from the ability to conceal their activities and exploit loopholes to manipulate the market.

Businesses targeted by predatory investment companies should have the means to determine where these attacks are coming from in order to defend themselves. Short-sellers currently operate to destroy businesses by driving their stock price down, doing business 'in the dark' and utilizing media to spread fear and misunderstanding about their intended victims. Businesses subjected to these tactics without knowledge of the source have no more hope than a mugging victim in a back alley.

Retail investors deserve to know the movement of predatory investment companies. Retail investors put up their hard-earned cash to support businesses they expect will do well. Without knowledge of the manipulation by short-sellers and other predatory companies, retail is not only deprived of the opportunity to make their own due diligence, but just as victimized as the targeted businesses themselves.

Retail investors are taking it upon themselves to investigate, communicate, and act upon ever-increasing knowledge about the mechanics of the stock market. I'm a 70-year-old investor and have never seen anything like this during my lifetime. This movement is not going to stop, and the new public scrutiny is going to expose more and more of what has, until now, been 'behind the scenes' predatory investment company behaviors. The SEC has a powerful new force in its arsenal if it chooses to embrace this world-wide network of investigators, at no cost to the government. Better for the SEC to utilize this ever-increasing information than to support the entrenched predators that the retail investors are investigating.

Currently it seems that the 'dark market' activities have entered dangerous new ground, where massive fraud and manipulation threaten the entire national security and world economy. Where the only goal of a company is profit without regard for consequences, any action is justified. Rules are ignored and fines are considered a cost of doing business. Within such a system of increasing obligation and manipulation, the economy becomes ever more precarious until an event occurs to precipitate a massive collapse. History proves this, and yet the events continue.

Every and any change to combat this activity should be encouraged. Not only for the health of the economy, but for the sake of the people and businesses who work and create the wealth of this nation. If you have children who are not inheritors of generational wealth, look at them and consider what their economic future will be if this predatory system is allowed to continue unchecked.