Aug. 16, 2022
August 16, 2022 1) I explicitly support transaction-by-transaction reporting because it eliminates the ability to \"hide within the aggregate\" transparency means transparency, and aggregates are not transparent. 2) I explicitly support the 15-minute reporting requirement, saying the cost and effort are justified to prevent fraud and prevent hiding in loopholes. 3) I explicitly say that victimized companies need a greater ability to defend themselves against predators and that \"short selling in the dark\" harms true competition and price discovery. The idea that a small number of short-selling funds \"know best\" and can hammer unsuspecting companies in the dark is shameful. 4) Retail will benefit from increased transparency. We have a better idea of the risks of our decisions and transactions if we can see who has targeted which companies. If funds are allowed to short in the dark, retail investors remain dangerously unaware of the risks they take on when purchasing securities. 5) There is a new and desirable phenomenon of the public serving as first-line watchdogs in monitoring short-selling data for securities fraud, strengthening the SEC and better enabling it to fulfill its mandate at no cost. 6) There are dangers inherent in long, untracked lending chains that can lead to economic fragility. Securities lending activity can hide massively destructive chains of obligation that threaten national security. So transparency in this area is more critical than it has ever been.