Subject: S7-18-21: WebForm Comments from Nathan McGinnis
From: Nathan McGinnis
Affiliation:

Oct. 14, 2022

October 14, 2022

 I vehemently support transaction-by-transaction reporting. I find it completely absurd hedgefund managers and market makers are opposed to stricter reporting standards. They obviously have something to hide. I think we can all read between the lines here. Only reporting aggregate allows deceit. Transparency means transparency and aggregates are not transparent.

In addition to transaction-by-transaction, we MUST require them to report EVERY 15 minutes The cost and effort are justified to prevent fraud and prevent hiding in loopholes.

There have been countless companies victimized by shortsellers (hedgefund managers, market makers) greed. To help prevent this from continuing, these companies need a greater ability to defend themselves against predators. By not requiring them to report every 15 minutes, transaction-by-transaction (NOT AGGREGATES), short sellers trade in the dark and destroy one of the basic fundamentals of our market: price discovery. The idea that a small number of short selling funds \"know best\" and can hammer unsuspecting companies in the dark is shameful.

Retail NEEDS greater transparency. We have a very limited ability to gauge risks if we can't see who is targeting what company. If funds are allowed to short in the dark, retail investors remain dangerously unaware of the risks they take on when purchasing securities.

Over the past year and a half, retail (read: the general public) has been taking an increasingly larger role in monitoring short seller activity. We have the research, we have some data points, but we need MORE data to continue serving as first-line watchdogs in monitoring short selling data for securities fraud. Making it mandatory to provide this data will only strengthen the SEC and better enabling it to fulfill its mandate, at no cost.

Long and untracked lending chains are leading to economic fragility. Securities lending activity can hide massively destructive chains of obligation that can even be a threat to national security, and so transparency in this area is more important than it has ever been.

As a retail investor, I urge the SEC to require greater transparency of short seller activities. Require them to report each transaction, every 15 minutes, and not an aggregate. Companies have been taking beatings (Bankrupt and Cellar Boxed) for far too long from fraudulent short seller practices, which serves no purpose in society.