Oct. 09, 2022
October 9, 2022
I strongly support implementation of Rule 10c-1.
When short selling practices occur in obfuscated markets and short sale information is provided long after a position has been entered into, unless privy to internal information, investors cannot be aware of the risks that they take on when buying securities. This lack of information represents a problem for all investors, who are expected to invest on incomplete and purposely delayed short sale information. I strongly support the intraday 15 minute reporting requirement. The cost and effort involved with conforming to this requirement is justified to help in early identification of abusive shorting practices, to reduce the ability of market participants to hide behind loopholes and to attempt to prevent such fraud occurring in the capital markets.
The new rule would also provide any victimised companies a greater ability to defend themselves against predatory short selling, as short selling in the dark pool harms true competition and price discovery. The enactment of this rule would also introduce the ability for public as well as public companies to participate as an initial line of defense against abusive short selling practices, by being able to monitor relevant data for securities fraud for those securities they are invested in. The recent years have shown that the SEC and the markets are not perfect and this is an opportunity to strengthen trust and reduce the stranglehold nefarious parties have on certain practices, at no additional cost to the SEC.
I am a strong supporter of transaction by transaction reporting. It is clear that aggregated reporting is not transparent in todays trading world, and provides far too much leeway where securities fraud can be hidden in aggregates. It is wholly unfair and contrary to the requirement of best execution and so it should be a mandated requirement for transaction by transaction reporting.
Regards,
Alastair