Aug. 16, 2022
August 16, 2022 To whom it may concern, I have read some of the comments proposed by some of the institutional market participants, and their opinions on this proposed ruling, and I urge the commission to consider the motivations of those who would like to narrow the scope of the proposed ruling, or do away with it altogether. The largest and most influential market participants already have access to incredibly sophisticated trading strategies and technologies, vast amounts of capital, and a wealth of information that unarguably provide them a significant advantage over competing market participants, especially the working class individuals that form the backbone of our markets. The proposed ruling would increase transparency around lending markets and short sale transactions, in a progressive and equitable way, to the benefit of many. It is absolutely imperative that transparency and fairness are prioritized over the profitability of individual market participants, and I ask the commission to consider if it is reasonable for institutions to benefit so significantly from lack of transparency regarding their trading activity, that they seek to hinder regulatory progress that is intended to increase equity, transparency, and fairness for all market participants. The key point here is that, even in the case that profitably is negatively impacted in the short term, it is tangibly beneficial for the long term health of the markets that investors have access to more information, are held accountable, and operate in the light. This way, investing can eventually become an accessible form of wealth creation for everyone, rather than only those who are already incredibly wealthy. Trading strategies that depend on opaque market structure and lack of regulatory action in order to return profits need not be spared. It should be in the interests of the commission that market participants are operating within fair and equitable conditions, and respect the laws that ensure a level playing field for all, rather than fighting to remain in the shadows. Opaqueness and lack of regulation in lending markets and surrounding short sale transactions are significant factors in the popularity of what some analysts call (meme stocks), and allow large market participants to create systemic risk in the name of profit, while depending on the commission and other regulatory bodies to ensure that they do not face the consequences of their actions. It is clear that the commission is interested in preventing short selling from continuing to create systemic risk, and increasing investor knowledge on how short selling impacts the price discovery of securities. Increased transparency would be a step in the right direction, and would severely undercut the potential for the spread of misinformation surrounding securities lending and short selling. An educated and knowledgeable investor base is essential to the health of the markets, and those who stand to gain from retail investors remaining in the dark, while simultaneously claiming to represent their best interests, ought to be scrutinized thoroughly. I urge the commission to hold fast, and not budge on its proposed ruling, keeping in mind its duty to the American people, and obligation to fight for fairer and more equitable markets for all. Thank you for your time. Sincerely, John F. Dempster II