Subject: S7-15-23: Webform Comments from Cory
From: Cory
Affiliation:

Sep. 19, 2023

I strongly support this proposal: 

In the ever-evolving financial landscape, the Securities and Exchange
Commission (SEC) is proposing a comprehensive set of rule and form
amendments known as "EDGAR Next"; to modernize the Electronic
Data Gathering, Analysis, and Retrieval system (EDGAR). This proposal
is driven by the imperative to enhance transparency, accountability,
and security in financial reporting. It is also essential in
addressing the emerging challenges posed by machine manipulation of
markets and the potential for criminal activity that can be falsely
attributed to machines. This essay presents a persuasive case for the
adoption of these proposed reforms.

The Threat of Machine Manipulation

1. **Market Manipulation by Automated Systems**

The rise of high-frequency trading and automated algorithms has
introduced a new dimension of risk to financial markets. Machines can
execute trades at speeds inconceivable to humans, enabling market
manipulation strategies that were once unimaginable. Instances of
flash crashes and sudden, extreme price fluctuations underscore the
urgency of implementing comprehensive measures to protect market
integrity.

2. **Crime and Machine-Driven Fraud**

Automated systems can also be exploited for fraudulent activities.
Malicious actors can use algorithms to disseminate false information,
execute manipulative trades, and engage in pump-and-dump schemes. This
type of criminal activity can undermine investor confidence and
distort market fundamentals, resulting in significant financial losses
for unsuspecting participants.

The Role of EDGAR Next in Mitigating Risks

1. **Accountability and Control through Designated Administrators**

One of the cornerstones of EDGAR Next is the requirement for filers to
designate account administrators. This measure enhances accountability
by ensuring that authorized individuals are responsible for account
management. In an era of machine-driven manipulation, this human
oversight is crucial for detecting and preventing illicit activities.

2. **Secure Individual Account Credentials**

To strengthen security, the proposal mandates that account
administrators obtain individual account credentials through specified
methods outlined in the EDGAR Filer Manual. This stringent requirement
is essential to verify the identity and legitimacy of those managing
financial data, mitigating the risk of unauthorized access and fraud.

3. **Streamlined Account Management for Timely Oversight**

The proposed dashboard on EDGAR provides filers with a centralized hub
for efficient account management. This streamlined approach simplifies
tasks such as filing submissions, data retrieval, and account updates.
Prompt oversight and management of account activities are essential
for identifying and addressing potential issues arising from
machine-driven market manipulation.

4. **APIs for Secure Machine-to-Machine Communication**

The introduction of optional APIs for machine-to-machine communication
is a transformative feature of EDGAR Next. While automated systems can
pose risks, they can also be harnessed to enhance compliance and
reporting. By offering secure APIs, the SEC empowers filers to
automate submission processes, reducing the likelihood of manual
errors and enhancing data accuracy.

Countering False Attributions

1. **Human Oversight as a Safeguard**

The human element introduced by designated account administrators
ensures that any market activity can be scrutinized for potential
manipulation or fraud. This safeguard is critical for distinguishing
between legitimate automated trading strategies and illicit
activities, thereby preventing false attributions.

2. **Access Control and Audit Trails**

The individual account credentials required by EDGAR Next create a
comprehensive audit trail. In cases where suspicious activities are
detected, these credentials provide a means to trace transactions and
account changes back to authorized individuals. This transparency
helps investigators differentiate between legitimate and criminal
actions.

Conclusion

The proposed "EDGAR Next" reforms represent a vital step
forward in enhancing transparency, accountability, and security in
financial reporting. As financial markets become increasingly
susceptible to machine manipulation and fraudulent activities, it is
imperative that regulatory bodies like the SEC adapt to address these
challenges comprehensively.

By requiring designated account administrators, mandating secure
individual account credentials, streamlining account management, and
offering secure APIs for machine-to-machine communication, this
proposal strengthens the SEC&'s ability to safeguard market
integrity. It also provides mechanisms to counter false attributions
of illicit activities to machines.

In a world where machines play an ever-expanding role in financial
markets, the adoption of these proposed reforms is not just prudent
but necessary to protect investors, maintain market integrity, and
ensure the continued stability of the financial industry.