Subject: S7-18-21: WebForm Comments from Jeremy Swope
From: Jeremy Swope
Affiliation:

Oct. 29, 2022


October 29, 2022

  I agree with proposed rule S7-18-21 (Rule 10c-1). I agree with the text that enforcement of this rule could \"provide a more complete and timely picture of trading, including interest in short selling and price discovery for securities lending\" and therefore be worthwhile to the market and its participants. It is difficult to get a full picture of the market without knowing where the securities are flowing.
  The 15 minute reporting window seems a bit generous given the speed of HFT's, which can easily adjust their entire portfolio in that time. But the rule is a good first step.

 - Jeremy