Subject: S7-18-21: WebForm Comments from Petur B Petursson
From: Petur B Petursson
Affiliation: Individual investor

Oct. 08, 2022



October 8, 2022

 I support transaction-by-transaction reporting because this would lead to a healthier market for a number of reasons.

Currently, there is a lack of transparency as securities reporting has been allowed to e.g. be done with aggregates and the combined positions of market players. This may have been done for practical reasons in the past, with technology having been slower and high speed communications not as common.
Nowadays, however, this is not the case so there is no reason from a technical standpoint why reports on transactions can't be done in a timely fashion.

As it stands, companies and/or funds can mislead and in some cases abuse the market by hiding their true transactions within aggregates and thus avoid reporting on them.
It may be that it's done just to save time and work on reporting, and not with any ill intent, but there is always the chance for those who want to use the loophole to do so.

If the goal is a healthy and transparent market, then the proposed change should be accepted. Even if this may make short selling more expensive or reporting a little more troublesome, the benefits far outweigh the risks that lax transparency and inaccurate or straight up misleading reporting imposes on our markets, as we've seen before.