Oct. 08, 2022
October 8, 2022
Dear Secretary Countryman:
I am writing in strong support of rule 10c-1, Reporting of Securities Loans.
Anyone arguing against additional transparency in the market, is clearly benefiting from their
ability to deceive that market.
Information is a valuable resource, and when institutions are allowed access to data that retail
investors are not, they are given an unfair market advantage. This is why the markets need
transaction-to-transaction reporting, where every detail is made readily available to the public.
This will level the playing field for the average working American, something Wall Street
desperately needs during this era of disturbing wealth consolidation.
I heavily support the 15 minute reporting intervals brought forward with this filing, as I believe it
is a step in the right direction to achieving transparent markets that allow small unsophisticated
investors to operate on a more level playing field with large institutions. This is why the market
exists. This is why America exists. It is not to line the pockets of the ultra wealthy, it is to give
hard working American families access to the profits of those American corporations that they
choose to support. The markets should exist as an avenue for enriching everyday Americans.
Currently our markets function better as a porthole into the pocket books of those same
Americans, for hedge funds and market makers to loot their hard earned money from under
their noses.
Short sellers are not investors, and in fact, they are exactly the opposite of investors. The SEC
should prioritize protecting actual investors first and foremost, as they are what create the basis
for a healthy and functioning market. It concerns me that the SEC has clearly shown their intent
to support the short sellers is greater than their intent to support the actual investors that they
leach off of. Short sellers' ability to operate in the dark is exactly why they consistently find
themselves in heavily overleveraged positions. Greater reporting transparency will reel-in the
enticement to make these absurd bets and should cool the shorting market, something
American companies could certainly use during a recession.
As a corporate executive myself, I am currently reconsidering my original business plan, in
which my ultimate end goal was an IPO on a US stock exchange. Now that I know how short
sellers can abuse companies, even successful ones, driving them into bankruptcy, I no longer
wish to bring my company onto an American exchange. This should concern the SEC to an
extreme degree. Average people are losing faith in your ability to regulate the American
markets, and those people will be taking their companies and their money elsewhere the
second they have an opportunity to do so, if you do not get a handle on this abusive short
selling.
There are already likely massive systemic risks looming underneath the carpet of market
transparency, and unfortunately for you, simply keeping it under the rug will not make the
problem go away. In fact, the problem is likely growing every day at an exponential rate, and
may even already be beyond the point of fixable. I am struggling to find words that carry the
correct weight for what I am about to say: Peoples LIVES are in your hands. If this gets out of
control and your ignorance of this issue pushes millions more across the poverty line and into
starvation, then it could not be denied that their blood will be on your hands. I hope you can
appreciate what I am saying here
Adding transparency to our markets is simply the most effective way to drive out the
controversial activities taking place inside of it. This is why I urge you to immediately approve
and adopt rule 10c-1.
Sincerely,
Shaun Boyajian