Subject: S7-18-21: WebForm Comments from Ryan Hovivian
From: Ryan Hovivian
Affiliation:

Oct. 08, 2022



October 8, 2022

 I am writing to you to show concern over the transparency of our financial markets. Right now, short sale data is old and slow. It does not give the full picture as to how heavily shorted a company may be. This is concerning for retail investors looking to invest in securities, as well as these companies being targeted by predatory short selling. How can one make a decision with incomplete data? Having these firms reporting their shorts and lending practices every 15 minutes, ensures that markets are more fair. There are too many loopholes that these firms hide behind, and in reality, hurt the every day investor financially. Aggregate reporting does not help retail investors chances of buying securities with good data.

The arguement that hedge funds are making, are invalid. Knowing someones shorting practices, levels the playing field. It does not give away their strategy, besides shining a light on how crooked they are and which companies they're targeting. The arguement that reporting every 15 minutes is too costly, is also incorrect. There should be no talk of cost when the topic is of market transparency. These arguments are coming from predatory short sellers, who have for too long enjoyed hiding in the dark. If the SEC's true goal is to make markets fairer, this reporting of short sales every 15 minutes will certainly move closer to that goal. I support enacting rule S7-18-22, ensuring predatory short selling is a thing of the past. This will ensure that innovation will no longer be stifled by these short sellers. The graveyard of promising companies with promising solutions to everyday problems, is filled to capacity. No more. Please support and pass rule S7-18-21. Thank you.