Subject: S7-18-21: WebForm Comments from Gabriel Nadal
From: Gabriel Nadal
Affiliation:

Oct. 08, 2022



October 8, 2022

 I support the 15 minute intraday reporting. Many times, the individual investor is left in the dark, as dark pool trading and secrecy move the price as they like without having to report to anyone.


The cost and effort it would take for this new rule to take place will quickly be compensated by the early detection of fraudulent activities.

Companies that are victims of abusive short sellers would also benefit GREATLY from this.

And I quote

 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 requireme V or transaction by transaction reporting.


And in your own words

\"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 13-2, 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 stock's 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.'\"