Oct. 26, 2022
To Vanessa A. Countryman (& whom else it may concern), I fully support the proposed measures - and I do believe it is a step in the right direction. 'The lack of transparency around short positions, the inability to adequately quantify short interest, and the ability for firms to skirt regulation through derivative positions such as options and security-based swaps are making a mockery of our free and open markets. The inadequate ability to properly measure and understand economic short exposure leads to supply/demand imbalances in markets and affects trading prices.' - We The Investors Retail investors (such as myself) do not feel comfortable investing in the US capital markets for these reasons. The closest equivalent I can make is jumping into a body of water without being able to see the depth, as the waters are far too murky. The proposed measures would provide investors with some much needed 'clarity' and reduce risk for all participants. It's rather obnoxious to see pushback from these Institutional firms that skirt these regulations, citing arguments such as 'increased compliance costs' etc - while High Frequency Trading operations occur within micro-seconds. I would argue that the increased risk given to other market participants for the current reporting lag far outweighs the potential increases they are so vehemently opposed to. The technology is not costly or difficult to implement - rather its the proposed requirement of inclusion of data, that which the exclusion of has been to their benefit for years and years. I believe it is highly important that the Proposal’s provision that would “require CAT reporting firms that are reporting short sales to indicate whether such reporting firm is asserting use of the bona fide market making exception under Regulation SHO” is included in the final rule proposal. Frequent violations of reporting by trading firms (i.e.mis-marking of short positions) have eroded participant trust. Actions taken by Self-Regulatory Organizations (such as the CTFC delaying swap data for several years on no real basis) have eroded trust. Investors are after greater transparency, please do your best to reduce risk and make the US capital markets a safer place for participants. Sincerely, Lewis Kitic Administration Co-ordinator