Subject: S7-18-21: WebForm Comments from Jonah Kraus
From: Jonah Kraus
Affiliation:

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 to voice my strong support of rule 10c-1, Reporting of Securities Loans.

It should be obvious to all observers that there is too much concentration of power in the hands of large hedge funds and financial institutions due to their ability to lobby government agencies and influence legislation and rulemaking to continue to rig the markets and give them an advantage over retail traders.

I believe it is no exaggeration to say that this concentration of power in our financial markets is a threat to national security. Americans have been losing faith in our government and democratic institutions at an alarming rate, even to the extent that we have seen what was previously unthinkable: the ransacking of our capital by a mob of violent, so-called patriots, who believed an alternate reality that the election was stolen from them.

When average Americans see the SEC ignoring their duty to protect retail investors, they become cynical and vulnerable to conspiracy theories. The fact that the SEC apparently lost the comments we already submitted in regards to this rule only adds to this sentiment. Whether they were genuinely lost due to incompetence or by nefarious means as a result of pressure from the hedge funds that stand to lose some advantage if this rule is passed, its very disheartening either way.

We need the SEC to pass rules that level the playing field and restore trust in our markets and then we need the SEC to enforce those rules with severe legal consequences including jail time for law breakers, rather than insignificant fines that are often not even collected and only amount to a small cost of doing business when they are.

One of the ways we can begin to level the playing field is by creating more transparency and access to data. Information is the most valuable resource and when institutions are allowed access to data that retail investors are denied, they are given an unfair market advantage. This is why the markets need transaction-to-transaction reporting and 15 minute intraday reporting intervals.

Working families need a safe place to invest their savings. What kind of nation allows banks and financial institutions to use deceptive trading tactics to siphon off value from pension funds and 401k accounts, or take on insanely large leveraged positions that crash the markets every 10-15 years and destroy the lives of millions of its citizens?

Entrepreneurs and innovators need a fair market so they can seek capital investment without fear of predatory, abusive short sellers bankrupting their companies using loopholes and loose reporting requirements to circumvent the law or the intent of the law. These short sellers are not investors in our markets. They are not adding value and building up our economy, companies and national wealth. They are taking huge profits by picking and choosing which companies succeed and which fail. They are diluting the value of companies by selling synthetic shares into the market and manipulating the prices of stocks. They are quite literally robbing investors with no consequences.

Due to lack of reporting requirements, these abusive short sellers are also creating systemic risk and hidden debt which represent threats to the global financial system. If there is another market crash because of their risky behavior, let these comments and the sustained efforts of so many retail advocates such as Dave Laurer bear witness that we all saw this coming and that YOU were warned. If you fail to act and pass this rule and further rules to end abusive shorting and the hidden mountain of debt it creates, the consequences will be on your hands.

If you truly want to protect working families and retail investors, please pass this rule and bring increased transparency to our market. If you continue to allow short sellers to operate in the dark, you are putting retail investors at risk.

Also, by providing more data to the investing public it will allow more sunshine to work as a disinfectant and help discover fraud and criminality. The SEC lacks the resources to adequately serve as a market watch dog. By publishing more data, you will enable all market participants to be vigilant and report crime if they see it. We need to engage the public and encourage and empower whistle blowers by giving them the data to see whats really happening in our markets.

For the sake of our markets, our democracy and our country, I urge you to immediately approve
and adopt rule 10c-1.

Sincerely,
Concerned Citizen