Aug. 16, 2022
August 16, 2022 I support transaction-by-transaction reporting because it makes reporting more transparent. Arguments made by past commenters stating that this rule will make it more costly to create short positions is not a valid argument against such a reporting requirement. Yes, we should strive to make it as cheap as possible for people to open positions, but not at the cost of blinding the rest of the market's participants' from discerning fraud when it takes place in the aggregate. Similarly, I support a 15 minute reporting requirement for increased transparency. The time, work and cost of such a rule should not outweigh transparency which will lead to efficiency in weeding out market fraud. Additionally, closing loopholes and ultimately strengthening the perception of the American market as fair and honest. These changes would likely bring back those who have lost trust in the American markets, and increase the trust in those that may otherwise lose trust. Information from the above rule changes would give everyone participating in the market the needed information to make informed decisions. This would allow them to avert otherwise unavoidable risk. These rules would improve the resiliency of companies who are under pressure by short sellers. This would lead to increased protection of shareholders long on those companies, who are not only institutional investors but retail investors. The latter being the most vulnerable in our markets. Short selling should not be subject to a different rule set from that of long positions. Continuing to allow those who are short such an unjustifiably unfair advantage is tantamount to theft of retail investors and the companies that run the United States economy. The past two years have shown that even with short sellers operating opaquely, public due diligence has uncovered alleged fraud by market participants. If 15 minute reporting requirement and transaction-by-transaction reporting were required, fraud prevention efforts through public inquiry would certainly provide a net positive from said rule changes. Saving Americans money. Arguably more important are the benefits to national security. When market participants are allowed to operate under opaque rules it allows for international fraud to occur, weakening our financial systems, which is the bedrock of economic growth and American strength. Rule in favor of transparency, not in weak arguments of increased cost. Rule in favor of increased public knowledge, not in fear of \"copycatting investment and trading strategies\" that may or may not increase diminished returns. Plainly, do what is right for America.