Oct. 21, 2022
Thank you for the opportunity to comment on this proposal. I would like to express my support for the proposed rule. In a free and fail market, transparency is necessary for price discovery, so any efforts to make our current market less opaque is welcome. It is my opinion that all short sale data should be reported and that reporting should be required for all market participants, not just investment managers at a certain level.
While the proposed rule is a step in the right direction, our markets will benefit from more stringent requirements. For instance, while the monthly reporting requirement proposed is a step in the right direction, more frequent reporting is better for ensuring all market participants have access to data in a timely and efficient manner. Increased access to data will promote appropriate risk management amongst participants and ensure market stability because their positions will be observable by all.
Additionally, I support a \"buy to close\" policy be enforced in addition to the \"buy to cover\" policy currently proposed. This will ensure the failure to deliver of stocks, which is currently rampant, is curtailed. There is no other situation in which a person would be allowed to fail to deliver a good that was purchased. The stock market should be no different.
Thank you for your consideration.
Sincerely,
William Bloxham