Oct. 08, 2022
October 8, 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. When short selling practices occur in the dark and 'current' short sale information is provided long after a position has been entered into, retail investors and the like cannot be aware of the risks that they take on when buying securities. You can understand why this lack of information would represent a problem for all investors, who are expected to invest on incomplete and dated short sale information. I support the intraday 15 minute reporting requirement. The cost and effort involved with this is justified to help in early identification of abusive shorting practices, to reduce the ability of toxic market participants to hide behind loopholes and to attempt to prevent such fraud occuring in the capital markets. The new rule would also provide any victimised companies a greater ability to defend themselves against predatory short selling, as short selling in the dark harms true competition and price discovery. The enactment of this rule would also introduce the ability for the general public as well as public companies to serve as watchdogs for the SEC as an initial line of defense against abusive practices, by being able to more granularly monitor short selling for securities fraud for those securities they are invested in, helping and strengthening the SEC's ability to fulfil it's mandate and to help weed out market participants that are working against SEC rules, all at no additional cost to the SEC. Short sellers are not investors, and in fact, they are exactly the opposite of investors. The SEC should prioritize protecting actual investors first and foremost, as they are what create the basis for a healthy and functioning market. It concerns me that the SEC has clearly shown their intent to support the short sellers is greater than their intent to support the actual investors that they leach off of. Short sellers' ability to operate in the dark is exactly why they consistently find themselves in heavily overleveraged positions. Greater reporting transparency will reel-in the enticement to make these absurd bets and should cool the shorting market, something American companies could certainly use during a recession. Adding transparency to our markets is simply the most effective way to drive out the controversial activities taking place inside of it. This is why I urge you to approve and adopt rule 10c-1. Sincerely, Concerned Retail Investor