Oct. 08, 2022
October 8, 2022 Dear SEC, I support this proposed rule requiring reporting of securities lending/short positions every 15 minutes. There are currently mininmal short position supporting requirements, in contrast to long position reporting requirements which are relatively much more robust. This information asymmetry can only harm retail. Retail investors should have a right to see who is shorting the companies they invest in, and in what quantity. Additionally, this reporting requirement should be enforced vigorously to prevent situations wherein some entity sells short more shares than should be possible given current ownership, or even sells short more shares have been issued by the company. Looking forward, once this rule is approved, further rules should be made to close loopholes allowing short entities to evade this short position reporting requirement, such as through the use of swaps or the \"family office\" exemption. For example, the CFTC inexplicably halted the publishing of swap data for all of 2022 and will only resume in 2023 (unless they delay reporting again.) How many short positions are hidden in this swap data?