Subject: S7-18-21: WebForm Comments from Edgat Ruiz
From: Edgat Ruiz
Affiliation:

Oct. 08, 2022


October 8, 2022

 Short selling is the opposite of investing, it is banking on a company to fall. I understand the arguement of short selling leading to price discovery in companies who's fundamentals or balance sheets may not be aligned with their current share price. However these companies should have a chance to improve their situations and have a chance to defend themselves against predatory short selling. One way to do this is to require more transparency on the short sellers end. By them being able to operate in the dark and very loose reporting requirements it is very obvious how easy it could be to abuse short selling, especially market makers and family office who seem to have even more laxed reporting duties. It also leaves retail in the dark and retail should be able to invest freely and with as much information as possible. Requiring short selling reporting every 15 minutes is a strong start to this and will hopefully level the playing field for everyone. If a billion dollar funds have t
 o create new strategies to stay profitbale because of this rule then so be it. The average retail investor is just trying to get ahead in life, so be it if the extra wealthy lose a bit for the sake of transperancy. Also if big short sellers are pushing back strongly against transparency rules what does that imply? What are they scared of? Isn't it just morally wrong for them to make huge profits by betting against companies and then not have to report it in a transparent way? Retail needs transparency and those who bend the rules need to be held responsible.