Oct. 09, 2022
October 9, 2022 October 8th, 2022 Vanessa Countryman, Secretary Securities and Exchange Commission 100 F Street, NE Washington, DC 20549-0609 Re: Reporting of Securities Loans (File No. S7-18-21) Dear Secretary Countryman: I am writing in strong support of rule 10c-1, Reporting of Securities Loans. Transaction by transaction reporting is an absolute must for transparency in the markets. The aggregation of positions can easily hide transactions that would affect investment patterns of actual investors were they to have the information that significant short selling is occurring, which would not happen were this not in place. Reporting must occur on as fast a timescale as possible, with the 15-minute reporting rule being sufficient to prevent fraud and abuse of any loopholes that can be found by delaying reports. Short selling is not investing. It is explicitly speculation, and is inherently harmful to any publicly traded business, and as an extension the working people who are their employees, and these people's families. If the SEC does not take action against the potential harm to retail investors and working families from the abuse that comes from the opaqueness of short sellers, then it is directly failing its own stated objectives. As it stands, the investing world is a dangerous place where a few companies holding vast wealth can attack a business they want to see fail purely to bring themselves profit through short selling attacks in the dark. This can appear as though investors are fleeing a company, while in reality no such thing is happening and investor confidence is high. This can cause investors to be spooked and sell off despite there being zero cause to the price movement before Wall Street can cash out. This awful, profiteering behaviour on the backs of the public needs to be cut off and companies given the opportunity to defend themselves from these malicious actors. While this can be done in the dark, there can be no investor confidence that there is any sort of price discovery or a fair market. Why is the SEC repeatedly defending short seller hedge funds on Wall Street, who are explicitly not included in the SEC's statement on their website. \"The SEC's long-standing tripartite missionto protect investors, maintain fair, orderly, and efficient markets, and facilitate capital formationremains our touchstone.\" These actors are not investors, they are speculators wishing for companies to fail and using bear raids, false information, and other malicious tactics you have stated as being a concern in the proposed rule 13f-2. All using highly risky financial instruments with other people's money and posing significant systemic risk. With the introduction of short single stock ETFs and repeated protections, delays of reporting, and a complete failure of any punishment more than a cut of profits, the SEC is putting forward a very strong image of being anti-investor and pro-abusive profiteering. This substantially raises the risk of short squeezes appearing across portfolios and wiping out large funds, leading to domino effects across the market. Without transparency in the markets, this will only get worse over time, and we need to guide so-called sophisticated investors away from taking such risk. Retail investors cannot be fully aware of what they are investing in if there is no transparency in the markets, which is the case at the moment. We cannot be aware of all of the risks of an investment while abusive short sellers can target and try to drag their investments down. We must have timely reporting to allow people to be able to be fully aware of market actions, rather than sacrificing the wealth people work hard to build up just so a hedge fund can get a better return. Right now, public trust domestically and internationally in the SEC is at an all time low. Claims of the SEC spearheading successful suits against fraud when they've not given any support to them, support given constantly to people attempting to destroy publicly traded companies for profit, and an incredible act of deleting retail's comments on previous proposals have left us feeling that absolutely nothing will be done to follow through with the SEC's mission. Working people and families will be robbed by wealthy hedge fund managers without any possible defence under the current rules. This regulations must be imposed to begin to restore confidence in the American markets. We cannot allow for the creation of long lending chains that can bring in huge systemic risks. Without timely, accurate reporting (confidence is already low with meagre fines for excessive misreporting), there will be extensive debt chains across the financial world from share lending in short sales. This leads us to be open for a severe amount of contagion risk due to the defaulting of a single member. Something much more likely as we head into recession and bear market territory. Sincerely, An Extremely Concerned Investor