Subject: S7-18-21: WebForm Comments from WB
From: WB
Affiliation:

Oct. 08, 2022



October 8, 2022
The SEC is an institution with an express mandate to protect retail \"Main Street\" investors. Such investors are already vulnerable to the predations of unscrupulous investing organizations on Wall Street which exploit loopholes in the law and regulations, lobby the government for exemptions or outright changes that benefit only themselves (often under the guise of \"liquidity\" or \"fair price discovery\"), and execute nefarious trading practices or outright criminal acts only to receive paltry fines years later- without \"admitting or denying\" any such culpability.

With S7-18-21, there is an opportunity to protect and act positively on behalf of the working families and everyday people that make up retail investors. I encourage the SEC very strongly to adopt and immediately enact the provisions of S7-18-21 without delay for the following reasons:

1. It will curtail the ability of nefarious organizations to hide trading data within the aggregate and make it much more transparent what is actually going on. As the saying goes, \"if you are doing nothing wrong, you have nothing to hide\".

2. The claim that the burden on organizations to report in 15 minute increments is too costly or overly burdensome does not stand when viewed in light of the fact these same organizations report millions, tens of millions, hundreds of millions, or even billions in profit. Surely any such costs are chump change.

3. Companies falling victim to predatory short selling will have greater means to defend themselves. Short sellers are not investors looking to the long-term success of the company. Predatory short sellers that abuse the many tools available to them bring only harm to the company specifically and to the markets as a whole generally, due to the increased fragility contained within long, untracked lending chains and swaps.

4. Retail investors who recall 2008 and their children who are now themselves becoming retail investors will be able to have greater data available to them which will assist in their ability to be aware of the risks involved in their trades. Making sound investment decisions is much more difficult to do when research tools and data are limited or locked behind high costs (Bloomberg terminals for example). The proposed rule will allow retail traders to guard themselves against Wall Street bad actors who only seek to siphon money away from \"dumb money\".

I sincerely hope the SEC and other regulatory organizations recognize the benefits of enacting S7-18-21 immediately. Such benefits go far beyond the short term and will last over the long term as greater transparency, market stability, and decreased fraud or \"errors\" will occur, resulting in a healthier market overall.