Aug. 16, 2022
August 16, 2022 I support transaction-by-transaction reporting because it eliminates the ability to \"hide within the aggregate\" transparency means transparency and aggregates are not transparent. I support the 15-minute reporting requirement, as the cost and effort are justified to prevent fraud and prevent hiding in loopholes. I believe 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. Retail investors 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. I believe in the new and very desirable phenomenon of the public serving 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. There are dangers inherent in long, untracked lending chains, and that can 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.