Oct. 29, 2022
October 29, 2022 Dear Gensler and the SEC team. I understand that implementing rules of reporting and compliance will increase costs and could endanger short sellers and market participants as others go against their position. But more transparency is always paramount. Today Market Makers such as citadel and virtu can see all of retail trades and positions that in itself is insider information when we do not know of their positions as well. Market makers may have paid for the data at brokers such as Robinhood. They can then call on their other branch to trade against retail and other investors with swaps and other derivatives. This is the main reason for High frequency trading which in 2010 Goldman sachs claimed their HFT code would be able to control the whole stock market if it fell into the wrong hands. You would need HFT algorithms and the trade data that brokers are willingly selling. PFOF purpose itself. Part of leveling the field to benefit retail investors is knowing what bets the larger players are making earlier as they have access to retail investment data before they make their own investments. This should be also done with internalization of broker stocks bought by retail. How much was on the open market vs how much was it internalized by said broker? The proposed rule of 5 days reporting period for 13d is good but not enough. Australia is a good example where it is 2 days rather than 5 days for reporting on greater than 5% stake in companies. I understand this may be at least a compromise until the market is adjusted to 5 days vs 2 days. I would push this through without delay and implement 2 day rules such as the rest of the world. Thus as a endnote transparency is always good and I would question the motive of anyone that disagrees with transparency especially the congressmen that submitted arguments against this rule. As congressmen implement rules on society the argument, If they are not doing anything wrong then they have nothing to hide. Then the reverse is true. Especially with greater congress and governmental official corruption with insider trading but not convicted and using loopholes to benefit from such insider knowledge. Thank you