Aug. 16, 2022
August 16, 2022 Transaction by transaction reporting of short sale information is an absolute must. In a public market, all information produced by such markets should be available to all participants. Specifically, if we have such data in one direction (long) we must also make available this data in both directions (short included). Aggregate data metrics are easily abused and can easily hide or distort reality, given that the vast majority of transactions on a daily basis are algorithmic and occur in fractions of a second. Furthermore, many opposers of the rule as proposed cite the technological and logistical headaches involved with advancing this proposal. However, given that the most advanced techniques, algorithms, real-time data feed etc, have been developed and employed in our markets, I expect firms can easily comply with this proposal. They will not want to do so as it would be a cost center for them rather than a profit generator. Additionally, the opposers cite the low value of this dat a. The potential value of data is determined not by the producer, but the consumers of such data. If real-time long data is beneficial, then real-time short data is beneficial. In this case, the public having access to detailed short data can help monitor and police the public markets. The last two years have shown that a subset of the investing public is quite capable of doing so, which would amplify the abilities of the SEC and make enforcement more efficient and effective. It's quite clear this rule would serve its purpose given the clear delineation between the entities who support vs oppose this. Finally, without such reporting, it will continue to be possible to infinitely dilute companies via rehypothecation. It is well known that securities of various types are lent and re-lent many times over. On it's own, current practices create the possibility and, now, the highly likely occurrence of short squeezes which may require intervention as \"infinite loss\" scenarios are increa singly probable. The bottom line is a lent security should not be able to be lent again. And while that is allowed, we must at least have a clear chain of custody to ensure abuse is limited, as well as over-voting and related corporate governance impacts are mitigated.