Subject: S7-18-21: WebForm Comments from Dustin
From: Dustin
Affiliation:

Oct. 08, 2022



October 8, 2022

 Hello and thank you for taking the time to read my comment which is strongly in favor of S7-18-21, specifically rule 10c-1.

Transparency is a must for a fair and orderly market. Especially in a day and age where retail investors are already at a significant disadvantage due to payment for order flow, high frequency trading algorithms, and \"coopetition\" between market makers, hedge funds, big banks, etc. The average retail investor stands little to no chance against machine learning algorithms specifically designed to trade in such a way as to elicit an often predictable emotional response from a typical trader.

The stock market is about capital formation and investing in a company you believe in. Short selling a stock is essentially anti-investing. It's a terrible concept to begin with but to think several large institutions have been caught shorting companies literally to death, is just heartbreaking. The lost capital, the consolidation of markets, the thousands upon thousands of average people out there who have lost their jobs to it. And while I'm aware that selling a stock short isn't inherently bad for that stock, the practice is often coupled with negative (sometimes completely fabricated) online press, groups of hired help that will trash a stock in online forums, illegal ladder attacks, etc.

If this weren't bad enough, large market participants have been quite laissez-faire, whether maliciously or ignorantly is irrelevant, about how many shares they sell short. On several occasions, companies have found excess shares numbering in the millions and even billions which were undoubtedly sold short. Potentially multiple times. Creating some grotesque daisy chain of human demoralization.

To summarize, transparency in the short selling market would do nothing but benefit retail investors. Even if you don't implement this for retail, having this type of consistent reporting could save the entire market from ruin. Imagine if someone shorted a company many times over and then retail bought and held that company's stock It could have huge implications for the market as a whole and the integrity of any enforcement agency in charge of making sure that doesn't happen.

Thank you for your time.