Oct. 08, 2022
October 8, 2022
Resubmitting after the comments were lost...
Hello,
Transaction-by-transaction and the 15 min reporting requirement absolutely needs to happen. T+X days is outdated and frankly insane. We have trading algorithms which function down to the nano-second and yet reporting on positions is far behind. The cost of implementing a system to handle such reporting may be great, but it is a necessity to protect companies targeted by short-selling.
Companies targeted by short-selling need a way to 'protect' or fortify themselves from these organizations who attempt to drive not only a stock price down, but ultimately a company out of business. The argument that short-selling promotes price discovery is laughable when in reality it's being used to completely ruin businesses.
Not only would companies targeted by short selling benefit from more transparency but so would retail. More (Accurate and timely) information is better. If funds are allowed to operate in a shroud of darkness how would someone make an informed investment? Retail oftentimes is making a dangerous gamble on a company without even knowing it because of the lack of information provided regarding short-sellers and their positions.
In your own words (proposed rule 13f-2), it was stated that there are a myriad of ways in which short selling can be used to abuse individual investors and working families.
Why is it that retail / 'working families' are the ones who have to push for better changes to the market? Time is an investment just as much as money, and a majority of retail are not able to spend the time needed to monitor a market that's stacked against them. The SEC needs more funds and eyes on issues that are directly impacting retail investors. Whatever it takes.