Subject: S7-21-21: WebForm Comments from Steven Mullins
From: Steven Mullins
Affiliation:

Oct. 08, 2022

October 8, 2022

 October 8th, 2022

Vanessa Countryman, Secretary
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-0609

Re: Reporting of Securities Loans (File No. S7-18-21)


Dear Secretary Countryman:

I am writing in strong support of rule 10c-1, Reporting of Securities Loans.

When short selling occurs in the dark and current short sale information is provided retail investors cannot be aware of the risks that they take on when buying securities. You can understand why the lack of information available causes such concern to all investors, who can only rely on dated and incomplete short sale information. I support intraday 15 minute reporting requirement. The price and effort involved with this is completely justified to help in early identification of abusive shorting practices, to reduce the ability of toxic market participants which seem to a have plague the market in recent years that hide behind loopholes and attempt to prevent such fraud occurring in the capital markets.

This new rule would give companies greater ability to defend themselves against such predatory short selling, as short in the dark harms true completion as a whole and price discovery. The implementation of this rule would also introduce the ability for the general public as well as public companies to serve as watchdogs for the sec as an initial line of defense against predatory practices, by being able to better keep track of short selling for securities  fraud for those securities they are invested in, helping and solidifying the SEC's ability to fulfill its mandate and to help highlight market participants that are working against the SEC rules, all at no additional cost the SEC.

 I strongly support transaction by transaction reporting. It is clear that aggregated reporting is not transparent  provides far to much rope where fraud can be hidden in aggregates. Right now the playing feels aren't level especially when one side suffers a worse execution whilst another benefits from a better execution, just because it is more convenient for certain institutions to report their short selling practices in the aggregate?. It's completely and utterly unfair and a goes against the free market which every investor, not matter how small or how big should stand on the same footing when it comes to best execution and so it should be a mandated requirement for transaction by transaction reporting.


Kind Regards,

A Concerned Investor