Oct. 09, 2022
October 9, 2022
Speaking as a retail investor I am in favor of this ruling as offering greater transparency in our markets to maintain it's integrity. I am concerned that the current lack of transparency in our market structure is leading to large institutions hiding in the aggregate with their short positions which dissuades actual investments as these institutions collect profits from real investors. Furthermore short selling without any transparency hurts competition and price discovery. I am also in support the of 15-minute reporting requirement.
The Commission points out these concerns in proposed rule 13f-2
...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.
The market is inherently less fair under the influence of aggregated reporting and it allows for an easy avenue for fraud. Having different speeds for execution is unfair and contrary to the requirement of best execution and so it should be a mandated requirement for transaction by transaction reporting.