Aug. 16, 2022
August 16, 2022
Dear SEC,
as a retail investor I am highly interested in the fair and open price discovery. In my mind the fairest and best way for this is full transparency or how much is possible based on technical and privacy reasons.
Based on this I highly support the proposed rule, since transaction based reporting in a high frequency will increase transparency. It would be even better if the detail was even greater.
As a software developer I also don't understand how it shouldn't be possible. All the information which is requested by the SEC should already exist in an digital form when the transaction is executed. So one would expect that it should be possible to generate a report of this data without much problems.
I would also suggest, that a standard format is defined by the commission so that this data can be easily parsed and compared by the SEC as part of their duties.
It would be great if the collected information would also be provided to the public in a timely and highly detailed matter.
Furthermore some comments were made about this proposal that it would increase the risk of practices like short selling. If the short selling is based on a solid evaluation of the company it shouldn't make a difference if this information is provided to the public as part of this regulation.
What probably isn't possible but would also be nice, if it would be possible to have similar reporting for \"failures to deliver\" (FTDs) or even link them. So that it may be possible to get insights about why and where FTDs get created initially. This would enable more regulations in the future to ensure a better market with less FTDs.
In general this rule would also decrease the amount of speculation by the media, since it would provide data about short selling at a specific point. Currently there will always be a discussion if a big player or many individuals maybe left an position. If instead drops in price for example can be linked to the opening of a short position, this removes this part of the speculation. Which will also lead to a fair price discovery and prevents fearmongering.
I hope you will enforce the rule as it is or even add additional requirements to increase the transparency.
Thank you very much for your work on improving the market.
Best Regards
Thomas S.
PS: Please enable international phone numbers in your online entry.