Oct. 08, 2022
Dear Secretary Countryman: I am writing in strong support of rule 10c-1, “Reporting of Securities Loans”. Transparence in free markets is essential. Transaction-by-transaction reporting eliminates the ability for bad actors to hide within the aggregate of the markets. Dark pool short selling goes against the ethics of a free and open market. The cost and time that would be involved in implementing the 15 minute reporting requirement is justified to prevent prevailing fraud and loophole abuse. The current practices of short selling take money directly out of the pocket of hard working American families and pools the nations wealth in the back pocket of those who need it the least. Companies that are attacked by these unethical market practices have no recourse in the current system. With everything happening behind closed doors, true competition and price discovery are pushed to the wayside. Unsuspecting companies, potentially world changing companies, are smashed in the ground before they can find there footings. With the lack of transparency, these companies are helpless in the hands of hedge fund giants that seek nothing more than to profit off the backs of others. Short sellers are not investors, they are sharks that look to victimize companies and retail investors. The SEC’s responsibility is to the everyday American, not to the hedge funds. Retail investors will benefit greatly from increased transparency. This rule will give retail a much better idea of the risks of each transaction and investment. As it is, we are blindly crossing the street, unaware of the short hedge fund bus flooring it down the block, inevitably flattening us as it passes. It is your duty as the first line of watch to protect those who cannot protect themselves. You are our eyes and ears in the market, and it is your responsibility to make sure all market participants are playing by the same set of rules. Ignorance of the problem is no longer an excuse, Gary Gensler has said himself that the vast majority of retail orders are flowed through the dark pools, not through the lit exchanges. As the SEC has said in the past “the Commission, in proposed rule 13f-2, explicitly noted its awareness of the myriad ways in which short selling can be used to abuse individual investors and working families. In proposed rule 13f-2, the Commission said it is “...mindful of concerns that certain short selling activity can be carried out pursuant to potentially abusive or manipulative schemes. For instance, market manipulators may seek to spread false information about an issuer whose stock they sold short in order to profit from a resulting decline in the stock’s price. The Commission has previously noted various other forms of manipulation that can be advanced by short sellers to illegally manipulate stock prices, such as ‘bear raids.’” Transaction by transaction will be a small step in the right direction of the market, but a step in the right direction none the less. There is no benefit to a less transparent market. The integrity of the market is essential to the global economy. Do the right thing. Sincerely, A concerned retail investor Sent from Mail for Windows