Aug. 16, 2022
August 16, 2022 I want to write in explicit support of transaction-by-transaction reporting as it has the highest level of transparency and prevents actors from \"hiding in the aggregate\". It is crucial for investors to know precise information on each transaction, allowing retail to better evaluate the risks of purchasing certain securities. Additionally the 15 minute reporting mandate carries a similar level of importance for providing information in time for investors to make decisions about major security purchasing decisions. While this carries some additional cost for those opening short positions, I firmly believe that the additional cost is worthwhile. Similarly this process should be very straight forward/automatable, I have a hard time seeing this incurring significant cost. Both of these mechanisms carry benefits for retail investors, targeted/shorted companies, and the SEC. As mentioned above, retail investors benefit from the increased transparency, allowing them to better judge the risk of individual securities. Companies that are the target of these shorts have better awareness of the factors effecting their stock price and are better able to compete in the marketplace with this more transparent reporting. This data also increases the ability to monitor short selling securities fraud, which enables the SEC to fulfill it's mandate more effectively. This data being publicly available means that the retail investors themselves can monitor this data and increase the effectiveness of the SEC without additional cost.