April 27, 2022
Please accept these comments in support of the proposals presented in Release No. 34-94313 Release No. 34-94314 File No. S7-08-22: Short Position and Short Activity Reporting by Institutional Investment Managers.
It is my opinion the proposals will serve the mission of the SEC by increasing transparency regarding short selling activity. On-going efforts by the SEC to increase market transparency and relieve information asymmetries promote efficiency, order, fairness, capital formation, and public trust. The result is an enhancement of investor ability to assess the market and make more informed decisions. Furthermore, the proposals will also boost the ability of the SEC to evaluate the efficacy of its regulations.
Monthly reporting will allow market participants to freely access information that will bolster understanding of patterns regarding the market and/or shorted securities and funds. The SEC made compelling arguments addressing potential burdens on managers and dealer brokers. I agree that the reporting threshold is such that it would affect entities with the resources necessary to address the additional requirements. Regardless, the requirements are in accordance with the SEC mission and pursuant to the Exchange Act and DFA and, if adopted, those subject to them should adapt and comply in service of the greater good for the market and all market participants.
Pursuant to the Exchange Act and Section 13(f)(2) added by the DFA, I urge the Commission to adopt the proposed rules (13f-2 and 205), proposed Form SHO, and amendments to CAT.
Thank you for your time and consideration and the opportunity to comment.