March 3, 2022
Hello and thanks for your time.
I am an individual investor, not affiliated with any organization. I'm not a financial expert or professional.
Rule S7-08-22 is an excellent addition to the SEC's tools for market regulation. I have skimmed most of the proposed changes to short-selling disclosure rules and would like to make clear one issue I have.
In section VII. Paperwork Reduction Act Analysis subsection F. Confidentiality I do not support \"that the information reported by Managers on Proposed Form SHO be aggregated prior to publication so as to protect the identity of reporting Managers\". I believe every Manager should be able and willing to put their name next to their investment and that the threshold to determine confidentiality should be the same for short positions as it is for long.
The reason I believe this is because the derivatives market has been abused and used for naked short selling and has maintained an opaque nature for far too long. It should be understood when considering the Regulatory Flexibility Act Certification that many Managers and Firms who experienced record breaking profits over the past 14 years, have done so at the expense of many viable and profitable private sector businesses. Through abusive \"naked short-selling\", \"cellar boxing\", and many other means, Managers and Firms have bled dry public sector businesses that could and would have supported the growth of the private sector. The tools they employ were born out of convolution and anonymity. It is necessary that these new rules level the playing field between all investors for the sake of creating a market capable of maintaining stability for generations, not just every ten years. A financial reset is close at our heels and I hope whoever reads this and all those at the SEC are prepared in every way to manage the reconstruction of our markets.
Thank you
Slava Ukraini
God Bless America