Oct. 30, 2022
October 30, 2022 Dear Commission, I support this proposal since every added transparency is improving the fair market and moving it closer to the definition of a perfect market. A more perfect market would reduce fraud and improve price discovery. I strongly support the reporting based on transaction, since the data should already be in the systems of the lending parties and it should be easily be able to disclose this data. And it prevents fraud and evasion of reporting, since it should display the lending which happens at it happened. Also the reporting every 15 minutes makes sense, since like mentioned before the data should already be there and it shouldn't be any problem to report it in a timely manner. Furthermore short selling can hurt the companies and works against the interest of the private and small investors of this companies. Because of this I think not only the reporting of short selling/ security lending must be improved, but also it must be made clear to an investor if their broker lends out their shares and educate them what this means for their investment. Currently uneducated investors are lured in by the promise of a small payment for lending out their stocks without realising that this in turn can lead to a lowered value of their stocks. This must be improved Also brokers should not be allowed to just disclose this information somewhere in their terms and conditions, but clearly communicate it Additionally it shouldn't be allowed that FTDs(Failure to deliver) can be closed by using shares which are lent by another broker/ market maker. Since this just moves the time it has to be returned. Instead FTDs should have to be closed by buying shares on a lit market. Just by providing the lending information in a high frequency this will enable the public, small investors and companies to have more knowledge and higher transparency in the markets, which will improve price discovery and prevent predatory behaviour of hedge funds. Best Regards Thomas S.