Aug. 16, 2022
August 16, 2022
Greetings,
I am a Danish citizen that is invested in the American stock market.
I support transaction-by-transaction reporting because it eliminates the ability to hide within the aggregate. Transparency means transparency and aggregates are not transparent.
Therefore i support the 15-minute reporting requirement. The increased costs and efforts related to following these requirements are more than justified, as it will help prevent fraud and bad actors from hiding in loopholes.
Retail investors like myself will benefit from this increased transparency. Retail investors will know more about the risks of their decisions and transactions, if they can see who is shorting 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.
Companies also need a greater ability to defend themselves against predatory short selling, and this 15-minute reporting requirement would increase their ablility to do so. Short selling in the dark harms true competition and price discovery. The idea that a small number of short-selling funds know best and are able to hammer unsuspecting companies in the dark is shameful.
In recent years, a new and very desirable phenomenon of the public serving as first-line watchdogs in monitoring short selling data has taken place. This can help identify securities fraud, strengthening the SEC and better enabling it to fulfill its mandate, at no cost. That phenomenon would benefit tremendously from a transaction-by-transaction, 15-minute reporting requirement.
I hope that this comment gives the SEC insight into the values of a retail investor, and that it can help you follow your own mission statement:
The mission of the SEC is to protect investors maintain fair, orderly, and efficient markets and facilitate capital formation. The SEC strives to promote a market environment that is worthy of the public's trust.
- Lars Seier