May 4, 2024
Subject: Comment Letter Regarding SEC Rule SR-OCC-2024-001: Opposing Lower Requirements for Short Sellers Dear Members of the U.S. Securities and Exchange Commission, We appreciate the opportunity to comment on SEC Rule SR-OCC-2024-001, specifically addressing the proposed lower requirements for short sellers. We strongly oppose the lowering of requirements for short selling, as it may exacerbate market volatility and negatively impact investor confidence. Short selling plays a critical role in maintaining market efficiency and liquidity, but it also has the potential to amplify market downturns and create systemic risks. By lowering the requirements for short selling, the SEC may inadvertently contribute to market instability and undermine the integrity of the financial system. This could lead to increased information asymmetry, allowing well-capitalized traders to exploit market inefficiencies at the expense of individual investors. Furthermore, the proposed rule change may discourage responsible innovation in the financial industry, as startups and emerging companies may face additional challenges in accessing capital and competing with established players. This could ultimately hinder the growth of new financial technologies and limit the benefits they bring to investors and the broader economy. We urge the SEC to carefully consider the potential consequences of lowering requirements for short sellers and instead focus on measures that promote responsible innovation, market stability, and investor protection. Thank you for your time and consideration. Sincerely, Lukasz Czarnota