Oct. 11, 2022
Resubmission of comments for S7-18-21 ---------- Forwarded message --------- From: M B Date: Tue, Jan 4, 2022 at 10:09 AM Subject: Release No. 34-93613; File No. S7-18-21 To: <rule-comments@sec.gov> Dear Sir/Madam, The reporting of short information has been a requirement of the Dodd-Frank act since the inception. That we are now in 2022 and it has not been implemented is a sign of just how much manipulation is happening within the market via shorts. The notion by Wall St. firms that reporting short data would be cumbersome and expensive is at best a disingenuous attempt to pretend that technology and automation have not evolved since 2008. The argument that it would cost more and that these costs would be passed on to end customers, in an automated environment is a flagrant attempt to make the commission believe that once implemented, the costs of running such a program would be so cumbersome as to be a burden upon all participants. Speaking as someone with over 25 years experience in IT, some of which was on Wall St., I can confidently say this, Wall St. will happily spend hundreds, if not billions of dollars if it makes them money, on the other hand, if spending that money results in a fair playing field for all investors, then they will deem it a burden and cumbersome. While at the same time, Wall St. will flagrantly and repeatedly bend, break and otherwise ignore regulations until it is discovered and they are fined, at which time, it is considered a cost of doing business. We are talking about firms that are already capable of self reporting, which in and of itself is problematic, not because reporting it is onerous, but because if a firm has a choice not to report data which might show manipulation on their part, they obviously will not do so. Automation of data reporting in a system which itself is already electronically based, is neither burdensome, nor likely to result in any meaningful or burdensome ongoing costs, to any participant. SROs have for too long been able to delay or add loopholes to rule introductions which serve no purpose other than to benefit themselves and tilt the investing market to their side. Arguing that less compliance is required in order to make the system, which is already horrendously broken is the direction to head, has time and time again shown that with less regulation, greed will win out and riskier and riskier complex trading setups will occur. All investments carry risks, whether you are a Hedge Fund or a Retail Investor - choosing to make an investment, you accept those risks. However, fair, timely and accurate access to reporting data to make an investment decision is fundamental to the market being fair to all participants. It currently is not. Failure to implement strict reporting guidelines with few, if any loopholes, including fines for misreporting and more serious consequences for ongoing abuse of improper or incorrect reports will continue to cause the market to be unbalanced and susceptible to volatility events.