Subject: S7-32-10: WebForm Comments from Anonymous
From: Anonymous
Affiliation:

Oct. 16, 2022

 October 16, 2022

   swaps need transparency because they can and are being used to hide short positions and skirt collateral requirements.

Transaction-by-transaction reporting should be implemented because it eliminates the ability to \"hide within the aggregate\". Unreported short selling could dissuade actual investment as funds attempt to glean profit off the backs of true investors. Substantial increases in transparency beyond all current rule changes to maintain trust of investors as well.


The SEC seems to be prioritizing hedge fund short sellers and  comfort and profiteering over investor protection and market transparency. While short sellers might be afraid of short squeezes that can follow the identification of their short selling strategy, that is not a reason for the Commission to decide against greater transparency. If short selling practices more transparent, then short squeezes and dangerous volatility become less common. Sophisticated investors will quickly learn to avoid positions that could result in such dangerous volatility, which will clearly benefit the market overall.


Retail will benefit from increased transparency. We have a much better idea of the risks of our decisions and transactions if we can see who is targeted which companies. If funds are allowed to short in the dark, retail investors remain dangerously unaware of the risks they take on when purchasing securities. More timely reporting allows for more efficient markets and price discovery. slower reporting prevents retail investors and working families from protecting themselves from abusive and predatory short selling practices.

The SEC chairs need to act quickly and be willing to face legal challenges from those that benefit from reduced transparency. In the long run it is important not to erode public trust beyond repair and also enforce existing rules more often and with harsher penalties that at minimum exceed the illicit gains.