Oct. 09, 2022
October 9, 2022 Dear SEC, I watched my parents and family members lose everything during the 08 crash because of Wall Streets abuse of the derivatives market and subsequent bail-out by Main Street investors. Ill never forget them watching their retirement accounts dry up and how that affected our life. While I agree with the direction of proposal S7-08-22, I feel it must be liberally amended in order to provide retail investors and institutions full transparency in both short activity and short positions. This would prevent anyone from losing track of the market and ultimately protect the market from another crash stemming from naked short selling in the derivatives market. Ive seen the news this weekend of margin calls coming in financial markets around the world. Will it really take another collapse and replacement as the World Reserve Currency Holder before we see the SEC get brave enough before they decide to establish and enforce policies that are liberal enough to actually promote the protection and security of the market? Transparency is CRITICAL for Price Discovery Per the proposed rule \"while short selling can serve useful market purposes, it also may be used to drive down the price of a security, to accelerate a declining market in a security, or to manipulate stock prices. FULL TRANSPARENCY in short activity and short positions would enable investors and market participants to properly effectuate market price discovery. Current market regulations allow short positions and short activity to occur that artificially increases the number of shares in circulation. This information affecting the supply of shares is not available to regulators, investors, or other market participants which facilitates stock price manipulation. An efficient market is one where information is disseminated quickly and efficiently to market participants. Thus, more frequent and accurate reporting is beneficial towards promoting an efficient market and stronger risk management. Short sale activity should be reported as quickly and as efficiently as possible in a manner at least equivalent to long position reporting to promote an efficient market, promote greater and more effective risk management, and reduce systemic risk. The new \"buy to cover\" order marking requirement is helpful to \"facilitate the collection of more comprehensive data on the lifecycle of short sales\" pg 54 for the Commission. However, a known problem revealed by the 2012 Rolling Stone article Accidentally Released and Incredibly Embarrassing Documents Show How Goldman et al Engaged in Naked Short Selling' (https://www.rollingstone.com/politics/politics-news/accidentally-released-and-incredibly-embarrassing-documents-show-how-goldman-et-al-engaged-in-naked-short-selling-244035/) is that some market participants (including Goldman Sachs and Bank of America/Merrill Lynch) manipulated supply and demand by intentionally creating fails-to-deliver on a targeted list of stocks including, for example, Overstock stock. These market manipulators used fraudulent trades to extend fails-to-deliver including matching trades to \"sell into\" required buy-ins. While marking a trade as \"buying to cover\" may reveal information beneficial to the Commission, this marking does not address the underlying issues where market manipulators have been and are skirting requirements to buy in to close short sales that failed to deliver. Simply put, there is no situation outside of Wall St where a fail to deliver would ever be tolerated. If a fully paid for security fails to deliver, there must be a hard requirement to buy-in and close that transaction. This is clearly within the regulatory power and scope of the SEC, who in the midst of the 2008 crisis issued new (interim) rules against abusive naked short selling primarily to protect troubled financial institutions. In order to have a clear and efficient market, there needs to be transparency for all investors. Main Street is not dumb money anymore and wont continue to stand for bail-outs on their dime, due to lax financial policy and companies operating on the too-big-to-fail get out of jail free model. This is a time for the SEC to seize this opportunity to seriously stand up for transparency and increase overall confidence/sentiment in the US stock market at a time where the future looks worse by the day. The financial crimes of todays derivatives market will be unveiled in due time. What side of the story does the SEC want to be on when it makes worldwide news? Honest investor