Oct. 08, 2022
October 8, 2022
I am writing vigorously supporting rule 10c-1, Reporting of Securities Loans.
I am a strong supporter of transaction-by-transaction reporting. Aggregated reporting is not transparent and provides far too much rope where fraud can be hidden in aggregates. Why should one individual or entity suffer a worse execution while another benefits from a better execution just because it is more convenient for certain institutions to report their short-selling practices in the aggregate? It is wholly unfair and contrary to the best execution requirement, so it should be a mandated requirement for transaction-by-transaction reporting.