Aug. 16, 2022
August 16, 2022 I understand that I am a bit late in commenting, however in regards to S7-18-21. Anything that supports transparency in the market is a wonderful thing and I am very much for the proposed rule. I understand there may be some perceived downsides in regards to costs associated with more comprehensive reports as well as shortened reporting times, in addition to possible disadvantages associated with disclosing investments to competitors earlier then preferred but the benefits greatly outweigh any disadvantage, for example: said competitors would also have to disclose positions making it a fair rule in that regard In addition lending practices automatically create a level of risk between the lender and buyer that other securities are rarely capable of producing, this risk is typically manageable but in many cases investors and businesses will use lending as a way leverage their assets well beyond what they can pay in the event of a potential default thus leading to risk being placed on other unrelated parties, as such I believe frequent non-aggregate and investor/institution specific reporting on these types of transactions/assets can improve the ability of the public and authorities to more quickly recognize and prevent horrific overleveraging that could lead to serious risk and economic damages in our markets. I would especially like to see short-selling REMAIN on the proposed rules list of reported items, as due to the lack of transparency in the markets naked short-selling is and has been rampant for decades and is/has been causing excessive and arguably manipulative levels financial damage to companies, and produces theoretically endless risk due to its structure. As such I believe the proposed rule to be excellent and I would love to see more aggressive transparency rulings in the future.