Oct. 08, 2022
October 8, 2022 October 8th, 2022 Vanessa Countryman, Secretary Securities and Exchange Commission 100 F Street, NE Washington, DC 20549-0609 Re: Reporting of Securities Loans (File No. S7-18-21) Dear Secretary Countryman: I am writing in strong support of rule 10c-1, Reporting of Securities Loans. I am a private investor who trades on the US capital markets, and I am writing to express my opinion regarding the SEC's proposed rule S7-18-21 for reporting securities loans. I want to call attention to the fact that several sizable institutions have commented on this rule, asking that it be removed or changed to a weaker version. Another blatant attempt by those who benefit from operating in the shadows and away from transparency to keep up their extremely profitable strategy. Some of these institutions have even said that this will negatively affect regular investors, which is plainly incorrect and, to be honest, rather a humiliating statement for any institution to say. It's quite evident that instead of acting in the interests of the market as a whole, these institutions are only repeating such untrue remarks in an effort to keep their profit margins high. Retail investors, pension funds, and other entities would greatly benefit from the proposed rule in its current form due to the greater openness. Before we make an investment, the rule would provide us a better picture of the dangers involved. Retail investors and other investors of the like cannot be aware of the dangers they take on when purchasing securities when short selling activities take place in the shadows and 'current' short sale information is published years after a position has been invested into. You can see how this informational gap would be problematic for all investors, who are expected to invest based on outdated and inaccurate information about short sales. The intraday 15-minute reporting requirement has my endorsement. To aid in the early detection of abusive shorting activities, to lessen the capacity of toxic market participants to hide behind loopholes, and to try to prevent such fraud from occurring in the capital markets, the expense and effort associated with this are justified. As predatory short selling hurts genuine competition and price discovery, the new law would also give any victimized companies a stronger defense against it. The adoption of this regulation would also grant the general public and publicly traded corporations the power to act as watchdogs for the SEC as a first line of defense against abusive practices. The SEC's ability to carry out its mandate and to help root out market participants who are acting in violation of SEC rules will be aided and strengthened by being able to more precisely monitor short selling for securities fraud for those securities they are invested in, all at no additional cost to the SEC. I firmly believe in reporting transactions by transactions. Aggregated reporting is obviously opaque and gives fraud much too much leeway to be covered up in aggregates. Why should one person or entity have to endure poorer execution while another person or entity reaps the benefits of superior execution simply because it makes sense for some institutions to report their short selling activities collectively? It should be a compulsory requirement for transaction by transaction reporting because it is completely unfair and goes against the objective of optimum execution. In order to enable all types of investors to better understand the risks associated with the investments they are making, before they are making them, I urge that the Short Sale Reporting regulation be implemented in its current configuration. Sincerely, A Concerned Investor