Subject: S7-18-21: WebForm Comments from Christopher Hopkins
From: Christopher Hopkins
Affiliation:

Oct. 08, 2022



October 8, 2022


- Explicitly support transaction-by-transaction reporting because iteliminates the ability to \"hide within the aggregate\" transparency means transparency and aggregates are not transparent. Secret short selling  the cost and effort are justified to prevent fraud and prevent hiding in loopholes.

- Talk about working families and everyday people that are victimized by financial predators. The SEC's new strategic plan(https://www.sec.gov/news/press-release/2022-148) puts \"working families\" front and center. This is good, and comes from the top, so let's hold them to it.

 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. Secret short selling hurts individual investors in the name of greater profits for hedge funds. Is that what the public would want from its government? Timely detection of fraudulent and abusive activity comes before Wall Street profiteering.

- A short seller is not an investor, but the opposite. The SEC seems to be prioritizing hedge fund comfort and profiteering over investor protection and market transparency. While short sellers might be afraid of short squeezes that can follow the identification of their short selling strategy, that is not a reason for the Commission to decide against greater transparency. If short selling is chilled, then short squeezes and dangerous volatility become less common. Sophisticated investors will quickly learn to avoid positions that could result in such dangerous volatility, which will clearly benefit the market overall.

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. More timely reporting allows for more timely reactions slower reporting prevents retail investors and working families from protecting themselves from abusive and predatory short selling practices. Working families and the individual investors need to be able to look both ways before they cross Wall Street. No one wants working families to get run over in the name of superior returns for hedge funds.

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. More timely, higher-resolution reporting would create a waterfall effect whereby some individual investors analyze the data and make that analysis publicly available for free, which is then disseminated widely and re-analyzed, spurring more activity. This allows individual investors to help each other, and allows busy working families to be the recipient of aid for free. Working families do not have the resources to buy data and analysis, nor do they have the time to analyze data themselves. Greater transparency has positive effects on investor protection that go far beyond the obvious. The Commission must not remain ignorant of how social media facilitates a protective web of information sharing that protects investors. The Commission must not behave as though they are ignorant of how greater data provision emp
 owers whistleblowers, who extend the Commissions reach and greater empower it to meet its strategic goals.

dangers inherent in long, untracked lending chains,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. The risks associated with reckless securities lending and short selling - highlighted with terrifying clarity following the events of Jan 28 2021, go far beyond any theoretical benefits of secret short selling for superior returns. Investor protection comes first.

 You can look at rule 10c-1(https://www.sec.gov/rules/proposed/2021/34-93613.pdf) or rule 13f-2(https://www.sec.gov/rules/proposed/2022/34-94313.pdf)for things to use.

the Commission, in proposed rule 13f-2, explicitly noted its awareness of the myriad ways in which short selling can be used to abuse individual investors and working families. In proposed rule 13f-2, the Commission said it is ...mindful of concerns that certain short selling activity can be carried out pursuant to potentially abusive or manipulative schemes. For instance, market manipulators may seek to spread false information about an issuer whose stock they sold short in order to profit from a resulting decline in the stocks price. The Commission has previously noted various other forms of manipulation that can be advanced by short sellers to illegally manipulate stock prices, such as bear raids.


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.

I am a strong supporter of transaction by transaction reporting. It is clear that aggregated reporting is not transparent and provides far too much rope where fraud can be hidden in aggregates. Why should one individual or entity have to suffer a worse execution whilst another individual or entity benefits from a better execution, just because it is more convenient for certain institutions to report their short selling practices in the aggregate? It is wholly unfair and contrary to the requirement of best execution and so it should be a mandated requirement for transaction by transaction reporting.

Why is the sec allowing citadel and other hedge funds to
Destroy our country ? The sec and everyone else knows about naked shorting. They literally are destroying companies and bankrupting them with FAKE SHARES Just to profit off of it . Meanwhile retail investors are  the only ones suffering as well the the families
Losing their jobs to green companies. Why isnt Gary Gensler doing anything about this when he knows for a fact what is going on . I think yall should  investigate him as well . Why are the swaps hidden until 2023 of October? I can go on. And I will as I will also be writing the DOJ You cannot allow this to keep going on. We know the stock market is fraud and s ponzu scheme and you know as well. Why isnt anything being done to stop this? Best believe me and hundered of thousands of others ( which will be millions and so on) will be fighting none day and night to get s free market . If you would like more proof of whats going on please feel free to contact me as I can send you to a site FULL OF DD LETTING YOU KNOW WHATS GOING ON

sincerely ,

A concerned investor(s)