Oct. 29, 2022
Proposed Rule 13f-2 requires reporting of short positions. The public absolutely wants this data. Please put an end to the ambiguity about short interest and short volume. The public deserves better data!!! Right now, the rule as proposed says funds and firms only have to report once a month. This is absurdly inadequate! It means the public will get daily activity, but 4-6 weeks late. That is completely unacceptable and needs to be changed immediately before being passed. If the Commission can propose every 15 minutes for securities lending in Proposed Rule 10c-1, they can and SHOULD propose DAILY disclosure for short selling of those lent securities. Short selling has serious negative consequences toward the price and value of securities they are used against. The public deserves to be able to properly evaluate the risks posed towards their investments, to be able to identify abusive short selling activity that would harm their investment in REAL TIME, thereby allowing them to react with timely & appropriate investment actions. Because of these serious consequences, it is my firm belief that the Commission should require daily public disclosure of short positions. The Commission should not do the bare minimum. Section 929X of Dodd-Frank states that the Commission must require reporting of short selling activity once per month AT A MINIMUM. It is my opinion that this represents far less than the bare minimum! If Proposed Rule 10c-1 can require intraday reporting of lending, then Proposed Rule 13f-2 at BARE MINIMUM can require DAILY reporting of short selling. Additionally, I emphatically demand public disclosure of ETF shorting activity also be included in this proposed rule change because they can be used to synthetically short vulnerable stocks and circumvent regulations. - A concerned investor