Oct. 09, 2022
October 9, 2022 Reporting of Securities Loans (File No. S7-18-21) Dear Secretary Countryman, I am corresponding to convey strong support of rule 10c-1, Reporting of Securities Loans. I very strongly support the intraday 15 minute reporting requirement. This rule is absolutely critical in creating a free and fair market, of which the Commission repeatedly echo's is the foundation of the US stock market. Unfortunately, the current market is fraught with abusive shorting. This rule is needed to reduce the ability of toxic market participants to hide behind loopholes and to attempt to prevent such fraud occurring in the capital markets. Current short selling practices are performed in the dark and the information is provided long after an individual has entered into a position. Performing hidden transactions completely undermines a free and fair market. If a hedge fund or market maker is creating legitimate and legal transactions, there would be no need for them to hide such transactions. The Commission stated, in proposed rule 13f-2, that it is aware of the myriad of ways in which short selling can be used to abuse individual investors and working families. In proposed rule 13f-2, the Commission said it is ...mindful of concerns that certain short selling activity can be carried out pursuant to potentially abusive or manipulative schemes. The new rule would also provide companies a greater ability to defend themselves against predatory short selling. Long delayed shorting selling data harms true competition and price discovery. The enactment of this rule would also introduce the ability for the general public as well as public companies to serve as watchdogs for the SEC as an initial line of defense against abusive practices, by being able to more granularly monitor short selling for securities fraud for those securities they are invested in, helping and strengthening the SEC's ability to fulfil it's mandate and to help weed out market participants that are working against SEC rules, all 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 and provides far too much rope where fraud can be hidden in aggregates. Why should one individual or entity have to suffer a worse execution whilst another individual or entity 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 requirement of best execution and so it should be a mandated requirement for transaction by transaction reporting. Thank you for your time.